Tax Base Defence: History and Reality
Journal
Country
International
Published Date
Issue
International Transfer Pricing Journal 2013 (Volume 20), No. 2
Document
The authors consider whether existing model treaties provide (i) protection for the tax base of the respective countries and (ii) guidance to MNEs for framing their effective tax rate strategies. The historical origin of the OECD and UN Model Conventions is presented, along with suggestions for a way forward under present circumstances.