The Economic Allocation of Income and the Disregarding of Narrowly Held Entities Following the OECD/G20 Base Erosion and Profit Shifting Project: Coordination of Work on Exchange of Information and Income Allocation Rules

The implications of developments regarding exchange of information rules together with changes to the international taxation regime have been underestimated. The use of economic concepts to exchange information relating to tax treaties could overapply economic and substance approaches in the allocation of income, thereby disregarding legal arrangements and persons.