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Tax Views: Taxation of multinational enterprises | Vern Krishna

Friday, March 02, 2018 @ 8:45 AM | By Vern Krishna

The taxation of multinational enterprises (MNEs) is of significant concern as countries are increasingly concerned with the erosion of their taxable base through profit shifting from high tax to low tax jurisdictions. Worries over tax avoidance led to the Base Erosion and Profit Sharing (BEPS) project by the Organisation for Economic Co-operation and Development (OECD). Encouraged by the heads of state of the G20 countries in 2013, the OECD drafted 15 BEPS action items.

Action 7 of the project involved “permanent establishments” (PEs) and their use...