October 2016 witnessed the release of 15 actions recommended by the Organisation for Economic Co-operation and Development (OECD) to contain tax base erosion through global profit shifting (BEPS). During 2017, these actions were discussed in international policy and academic circles and I, too, participated in conferences at Maastricht University in Amsterdam, Taxand in Frankfurt, Foundation for International Taxation (FIT) in Mumbai, and others. There was an approach of bracing the Actions with a certain adulation. Of course, there were some questions raised on what remained to be improved, for example, Action 1 on the taxation of the digital economy.
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