World events in the first decade of this century led many to question the state of the international tax regime and the role it could play in solving national fiscal problems. In 2012, leaders of the Group of 20 (G20) set the OECD an ambitious agenda of working out how tax base erosion and...

As part of the Organisation for Economic Co-operation and Development's Base Erosion and Profit Shifting project, country-by-country reporting (CbCR) has been promoted as a mechanism to enhance transparency with respect to the operations and tax planning activities of large multinational...

In 2013 the OECD released its 15-point action plan to deal with base erosion and profit shifting (BEPS), which recognised that BEPS has a significant effect on developing countries because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote...

In this article, the authors explain the compromise approach developed by courts when setting transfer prices for transactions where there are no actual comparable arm’s length prices and illustrate the process with recent examples from Australia