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Despite achieving unprecedented growth and profit rates, the digital economy seems to be relatively undertaxed when compared to more traditional 'bricks and mortar' companies. The current rules are based on the physical presence of taxpayers and assets, and there is a general understanding that they are not suited to taxing a digital economy characterised by reliance on intangible assets and ubiquitous services whose location is often hard to determine. International bodies are currently working ...

Action to fight corporate tax avoidance has been deemed necessary in the OECD forum, with further impetus from the G20/OECD 'Base erosion and profit shifting' action plan (known as BEPS), initiated in 2013. The BEPS action plan has 15 actions, covering elements used in corporate tax-avoidance practices and aggressive tax-planning schemes and was endorsed in 2015. The 15 BEPS final reports are generally seen as a step in the fight against corporate tax avoidance. The action against BEPS is designed ...

The tax reduction methods used by multinational companies have been well known for decades. They include transfer pricing, the use of lower-tax jurisdictions, over-charging entities in higher-tax countries to reduce taxable profit and (legally) completing a transaction in a lower-tax country, different to the country which the business relates to. The problem is relatively clear and law-makers want a situation where businesses not only operate within the letter but also the spirit of the law.