Practicing Experts' Views on BEPS: A Critical Analysis

In July 2013 the OECD, to tackle multinational tax avoidance, published its Action Plan against base erosion and profit shifting. The Action Plan suggests a variety of legislative and administrative measures to eliminate frictions from interactions between domestic tax laws and international tax treaties, including potential double non-taxation of businesses operating in several countries. By virtue of the OECD's structure, the proposed measures have been designed and developed predominantly by representatives from the tax administrations of OECD member countries. Our research investigates the views and opinions of other stakeholders in this process, namely tax experts from practice. We conduct a conjoint analysis, surveying experts in international taxation regarding their perceptions and beliefs on the effectiveness of the proposed actions. We find that experts rank actions that are aimed at enhancing international coordination and cooperation, as well as actions that reduce legal uncertainty, higher than other actions. Of lesser importance are antitreaty-abuse measures, further transparency at the taxpayer level and amendments to the definition of permanent establishment.