When the Organisation for Economic Co-operation and Development (OECD’s) Base Erosion and Profit Shifting (BEPS) project was launched in early 2013, there was some skepticism as to whether it would achieve much. After all, tax was still firmly a sovereign matter for countries with the occasional bilateral component (i.e. tax treaties). No focused multilateral initiative on tax issues had ever been attempted before on this scale, and some feared that this would not amount to anything more than an exercise in producing a few high-quality (if ultimately irrelevant) reports.
Still, in a span of hardly four years, the BEPS project
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