BEPS Project: Effectiveness for Developing Countries and How the World Bank and IMF Can Contribute

By Zoe Diamond

Zoe represented the UNSW Co-op Scholar Program at the 2015 World Bank and IMF Annual Meetings in Washington D.C. Zoe is studying a Bachelor of Commerce (Accounting and Finance). She has taken on industry internships with organisations such as Coca-Cola, Baycorp and the NSW Treasury in pursuit of her keen interest in corporate strategy and finance.

Abstract

Multinational enterprises (MNEs) engaging in corporate tax avoidance (CTA), or base erosion and profit shifting (BEPS) is a global issue. It affects the ability of both developing and developed countries alike to provide collective goods, infrastructure, education and healthcare. The impact of CTA is more severe for developing countries, however, as they are reliant on tax revenue from corporations to fund sustainable development outcomes such as the alleviation of poverty and providing access to basic sanitation. Current research recognises that developing countries face challenges in collecting tax. The lack of discourse addressing the disproportionate negative impact of CTA in developing countries is clearly evident.  This paper seeks to shed light on the impact CTA on developing countries and to propose recommendations to enable the World Bank and the International Monetary Fund (IMF) to supplement the multilateral effort to combat CTA. Firstly, the mechanisms of CTA will be briefly outlined. The key challenges faced by both developing countries and the multilateral organisations in combating CTA will then be examined. The effectiveness of the Organisation for Economic Cooperation and Development’s (OECD) BEPS Project for developing countries will then be examined. The role the World Bank and International Monetary Fund (IMF) are playing in this space will be analysed and recommendations will be provided as to how these organisations can contribute to more effective outcomes for developing countries.

Recommendations

For IMF and World Bank:

  • Invest in technological capacity and implement Compliance Risk Management (CRM) in tax administration systems of development countries
  • Increase data collection and reporting on CTA practices of MNEs in developing countries to facilitate greater transparency and awareness and in turn place greater reputation risks on companies engaging in these practices
  • Ensure that efforts are coordinated with BEPS project, rather than overlapping to maximise the effectiveness of allocated resources.

Introduction

Increasing media, political and public attention is spurring domestic and international debate on multinational CTA. This deficit in revenue occurs in both developing and developed countries. The impact on developing countries is much more severe though.[1]  In 2015, developing countries lost an estimated $US100 billion in corporate tax revenue from MNE’s BEPS practices, while in 2013, Oxfam estimated that extreme poverty could be eradicated for $US60 billion a year.[2] Ensuring that multinationals are taxed ‘where economic activities take place and value is created’, as called for by G20 leaders in the 2013 St Petersburg Tax Declaration,[3] will allow more domestic resources to be deployed to fund sustainable development.

In 2015, the United Nations proposed 17 Sustainable Development Goals (SDGs), which will provide a global development framework to succeed the Millennium Development goals, which conclude in 2015.[4] A key goal of the IMF and World Bank 2015 Annual Meetings in October is to determine how to facilitate international cooperation and progress toward the SDGs over the next decades.[5]  The Third International Conference on Financing for Development held in July 2015 suggested that in the coming decades there will be less focus on aid and more focus on building capacity within developing countries to generate their own financial resources, including taxation revenue.[6]

With the backing of the G20 Group of Nations, the OECD has taken the lead in the global community to tackle CTA through the BEPS Project and subsequent Action Plan.[7] This paper seeks to explore whether this plan will be effectiveness in reducing CTA and consequently the achievement of the SDGs in developing countries. Will also examine how the World Bank and IMF can assist in obtaining positive outcomes for developing countries in the BEPS space.

Methods of Corporate Tax Avoidance

BEPS are strategies which MNEs employ to shift their profits to low or zero-tax havens. Companies can reduce their tax liability in high-tax jurisdictions through intra-company transactions known as ‘transfer pricing’. Alternatively, subsidiaries in high-tax jurisdictions can be artificially loaded with inter-company debt, using interest repayments to reduce their taxable income. MNEs often pay very low or no tax on at least a proportion of their profits using these strategies.  Apple, the world’s largest MNE, received widespread criticism in the Australian media for paying $193 million in tax on $27 billion of Australian sales (0.7% of turnover) between 2002 and 2010.[8] BEPS strategies have reportedly enabled Apple to avoid paying tax on US$44 billion of global sales between 2010 and 2014.[9] 60% of all global trade is conducted by MNEs[10], highlighting the substantial opportunity to engage in CTA. While corporate tax minimisation and avoidance is legal, the ethical and corporate social responsibility implications of such practices are questionable.[11] The ethical implications are more difficult to ignore[12] when likelihood of achieving SDGs is reduced.

Impact of Corporate Tax Avoidance on Developing Countries

While corporate tax avoidance is a global issue, the negative impact on developing countries is much greater than on developed countries[13]. Economies in developing countries are largely informal and most transactions occur in cash.[14] Corporate tax is therefore a crucial component of tax revenue in developing countries because it is much easier to collect than income and consumption taxes.[15]  CTA also undermines the tax system and rule of law within the state, encouraging non-compliance throughout the economy.[16]

Taxation’s Role in Promoting Sustainable Development

Unlike foreign aid and loans, which often come with strict conditions including structural adjustment programs decreasing the autonomy of the state, tax revenues are free of such obligations.  Taxes are therefore the most durable resource to finance social infrastructure and economic and social development, consequently improving living standards for millions of people. Furthermore, financial aid to contribute to the achievement of MDG and SDG declined in the wake of the Global Financial Crisis (GFC) in 2008, placing more responsibility on developing countries to widen their own internal revenue base to fund development outcomes.[17] Increased taxation collection builds effective and accountable states and promotes a strong social contract between governments and citizens, which creates context for sustainable economic growth and development.[18]

Cost of Corporate Tax Avoidance

In 2015, the UN Conference on Trade and Commission (UNCTAC) estimated that US$450 billion of MNE profit is shifted out of developing countries annually.[19] The resulting $100 billion in lost tax revenue could finance Africa’s US$3 billion annual infrastructure funding gap[20] and is more than the total aid budget of the G7 nations in 2013 ($US94.8 billion).[21]  A study in Africa found that the ability to collect tax revenues is positively correlated with the achievement of the UN’s Millennium Development Goals[22]. In 2011 the OECD estimated that over half of the gap in funding required to achieve the MDGs could be recovered by improving corporate tax collection in developing countries,[23] further highlighting the importance of stemming the outflows of corporate profits.

Key Challenges for Developing Countries

Reliance on Foreign Direct Investment

Developing countries face a difficult trade off between attracting foreign direct investment (FDI) and collecting corporate tax revenue. Relying heavily on FDI for access to new technologies and developing an industrial base and funding investment.  In the absence of natural resources, skilled labour and effective legal and social institutions developing countries often look to tax subsidies to compete for FDI.[24] Offering tax subsidies to attract economic activity, however, has resulted in a narrowing of tax bases in developing countries, highlighting the detriment of these competing interests on domestic revenue.[25].

Weak Tax Administrative Systems

The tax administrative systems (TASs) in developing countries have failed to minimise CTA domestically. The OECD Development Working Group (DWG) found that the three key challenges developing countries face in combating BEPS are ineffective legislation, a lack of data and limited capacity to implement complex transfer-pricing rules and challenge well-resourced MNEs, which results in potentially more aggressive tax avoidance than in developed countries.[26] Under-resourced TASs means that tax policy must be simple to minimise administrative pressure and more susceptible to CTA.[27] A lack of technological investment, manual processing, limited data storage and difficulties in managing operations reduce compliance and increase corruption.[28] This is further compounded by a high turnover of experienced staff, decreasing skills within the organisations.[29] Funding is so unstable that tax authorities have suspended field audits because they could not afford auditors’ transportation costs.[30]

Average Effective Tax Rates

The recent trend among both developed and developing countries has been to cut average effective corporate tax rates.[31] Unlike developed countries, however, tax bases of developing countries have narrowed.[32] This suggests that developed countries are much better at targeting tax avoidance and providing cuts in the most efficient areas, whereas tax cuts and competition are ineffective for developing countries. Through forums such as the OECD, World Bank and IMF, there is scope for developed countries to assist developing countries effectively reform their tax system to widen the revenue base.

Key Challenges for the International Community

Outdated Complexity

Increased globalisation and rapid technological change has allowed MNEs to legally exploit loopholes in the global tax system.[33] The basis for international tax policy was designed by the League of Nations in the 1920s and allocates ‘residence’ and ‘source’ taxing rights.[34]  Residence rights are the rights of a jurisdiction to tax profits from whom the profit of a business flows to. Source rights are taxing the profits of the economic activity generated in a jurisdiction. Residence countries have primary right to tax passive income such as dividends, royalties and interest while source countries were assigned the right to tax income of the business whereas arguably adding unnecessary complexities and loopholes, which MNEs now exploit.[35]

Conflicting Domestic and Multilateral Interests

Borders do not confine financial flows. Tax law however, is still determined by individual jurisdictions. Countries use their tax policies to compete for increased economic activity, creating tension between national interests and the interest of the global community.  When countries cut effective tax rates, MNEs are incentivised to engage in aggressive BEPS to maximise profits. Therefore, as long as countries have an incentive to deviate from any international agreements in their own best interest, then the standards will not provide a sustainable long-term system, which will minimise the occurrence of CTA in developing countries.  In 2010, for example, the UK announced plans to slash corporate tax rates from 28% to 20% by 2015, in hopes of becoming the most competitive tax regime in the G20. The UK also holds an active role in the OECD development of the BEPS Action plan,[36] illustrating the conflict in interests between the global community and individual states.

Voting Rights

The funding of Multilateral Organisation (MOs) also creates bias in policy decisions favouring the interest of developed countries. The voting rights of member states in MOs are usually determined by the size of their funding contribution. The US, for example holds 16.74% of votes in the IMF, while Uganda only holds 0.10%.[37] Similarly, the US contributes 21% of the OECD’s €363 million budget.[38] The US also represents 51 of the top 100 MNEs,[39] which have an interest to maintain the status quo.  The assignment of voting rights creates an inherent bias for IOs to favour the interests of developed countries over developing countries. MOs have however, established internal bodies such as the G20’s Development Working Group to champion the interests of developing countries and facilitate greater engagement in policy making[40].

BEPS Project

The OECD

The OECD was established after World War II to encourage economic and policy cooperation among Western countries. One of the OECD’s primary goals is to promote cross-border investment, making combating CTA within its mandate.  The OECD is sometimes criticised for lacking the political power to legislate policy decisions.[41]

The G20

The G20 is comprised of nineteen member countries plus the European Union, representing 90% of global GDP. It is a forum for political leaders to discuss international economic cooperation and decision-making.[42] In 2013, in the wake of mounting criticism of CTA practices in member states, the G20 called on the OECD to deliver a report on BEPS. The BEPS partnership between G20 and OECD has been praised as a collaboration that combines technical expertise and political power, which expresses the need for global collaboration and cooperation.[43]

BEPS Action Plan

OECD and G20 have released 15 action items which address issues with taxation treaty abuse, hybrid mismatch arrangements, the digital economy, transfer pricing and country-by-country reporting (CBCR).[44] The fifteen deliverables in the OECD Action Plan largely seek to close loopholes in transfer pricing rules, potentially adding complexity, which will only make tax compliance harder to enforce in developing countries.[45] CBCR is an example of the limitations developing countries face in accessing the benefits intended to flow from the BEPS Project.[46] CBCR is a significant positive development in international taxation transparency forcing MNEs to disclose sales, profits and taxes in all jurisdictions.  This information will however, only be shared among taxation authorities to ensure confidentiality for MNEs. Developing countries may lack the administrative structure or capacity to facilitate this reciprocal exchange of information and level of confidentiality required to benefit from this information-exchange,[47] limiting the effectiveness of this action item for developing countries.

Developing Country Engagement

In 2014, the G20 Working Developing Group (DWG) criticised the BEPS Project for not including developing countries in research and policy development.[48]  In response, the OECD developed a ‘Strategy for Deepening Developing Country Engagement in the BEPS Project’.[49]  Consultations were held with 80 developing and other non-OECD countries in four regional meetings and five global forums. Fourteen countries from a cross-section of regions and per-capita income levels were also invited to directly participate in the Committee on Fiscal Affairs and the BEPS Project Working Party meetings. The OECD also established BEPS Project regional networks, which meet biannually to encourage developing countries to foster long-term engagement with BEPS Project and build on the success of initial consultations. The OECD is also developing toolkits, including reports, guidelines, and model legislation and training materials, which will support the practical implementation of the BEPS measures as well as recommendations on how to deal with taxation related issues outside the scope of the BEPS project highlighted in initial consultations with developing countries.[50]

While efforts have been made to ensure interests of developing countries are recognised in the BEPS Project, the effectiveness of these efforts is questionable.  This is demonstrated by calls to create a new UN agency and by a lack of engagement in the project in the Asia-Pacific region.  In 2014, Oxfam raised concerns that efforts to engage developing countries have been largely superficial.[51] Oxfam highlighted that out of the 15 policy proposals to espouse from BEPS, 7 were decided at the G20 forum held in Australia at which only G20 member nations were present.[52] At the UN Conference on Financing Development, developing nations and advocacy groups called on the UN to establish a new agency, to take the lead in the global effort to tackle tax in developing countries.[53] Concerns were also raised that the OECD, comprised of 34 developed member countries, is not a suitable forum to address the needs of developing countries. Switzerland, Luxembourg and Ireland are renowned corporate tax havens, are among the 24 member countries and have an interest in preserve the status quo.[54] Furthermore, KPMG conducted a survey of BEPS Project involvement in the Asia-Pacific region.[55] When levels of engagement in BEPS Project are compared with Human Development Index scores of these countries,[56] it is evident that it is the least developed countries that are also the least engaged with the BEPS project, as shown below.

Zoe Diamond Fig 1.jpg

Awareness and Transparency

This paper argues that effectiveness of the BEPS Project for developing countries has been derived from the increased transparency and awareness of CTA. This awareness creates reputational risk for MNEs engaging in aggressive CTA practices.  Deloitte conducted a survey of 559 staff from MNEs in over fifteen countries (largely developed) and found that 44% of respondents agreed or strongly agreed that their business had changed the way they conducted cross-border tax planning as result of proposed BEPS projection actions.[57]  A study conducted 2002, found that despite extensive CTA investigatory and punishment powers, the Chinese government still experienced high levels of BEPS.[58] This suggests that the solution goes beyond plugging regulatory loop holes and rather must come from a desire within companies to act responsibly and contribute taxation revenue to the societies in which economic value is generated.

Effectiveness for Developing Countries

In summary, the effectiveness of any global agreement to stem CTA, including the BEPS Project, is undermined by a country’s lack of adherence to global standards. Furthermore, the funding and assignment of voting rights in MOs favours developed countries. This is demonstrated in the BEPS 2014 deliverables, which have more favourable outcomes for developed countries, which have effective taxation administration systems and resources to implement reform. For developing countries, the BEPS project may potentially increase complexity and rules, decreasing capacity to enforce corporate taxation obligations on MNEs.

This paper argues that the effectiveness of the BEPS Action Plan is derived from increased transparency and awareness of CTA, increasing the public accountability of companies engaging in aggressing BEPS. BEPS Project promotes discussion of the moral and corporate social responsibility implications, at least within the developed world. Recommendations contained within this paper, largely seek to extend the scope of this awareness and discussion to include the impact of CTA on the developing world.

IMF and World Bank’s Current Role

Revenue mobilisation in developing countries is a key concern to the IMF and World Bank. The IMF describes it role in combating CTA as providing surveillance and technical assistance to help developing countries to build more effective and fairer taxation systems,[59] to facilitate and promote domestic government revenue sustainable development. In 2014, the IMF released a policy paper entitled ‘Spillovers In International Corporate Taxation’, which confirmed many of the findings of the BEPS Project giving broad, generic recommendations, including addressing weaknesses in domestic law and multilateral arrangements.[60] In 2013, the World Bank highlighted CTA as a significant risk to the development prospects and achievement of post-MDG outcomes of developing countries.[61]

In July 2015, the IMF and World Bank announced the established of a joint initiative to help developing countries strengthen their tax systems.  The initiative aims to facilitate more international debate and cooperation and develop tools, which can be used by member nations to evaluate and strengthen their domestic policies.[62] Recommendations within this paper focus on strengthening this initiative.

Recommendations for IMF and World Bank

Increase technological capacity and implement Compliance Risk Management (CRM) in tax administration systems.

Increasing the effectiveness of developing countries TASs will enable developing countries to maximise the potential benefit they obtain from the BEPS project. As identified in this paper, added complexity increases the strain on under-resourced tax administration systems and reduces compliance.  Improving the quality of TASs is also positively correlation with increased economic development.[63] The IMF and World Bank should seek to improve the quality of taxation administration systems by providing funding, training and technical skills to implement Compliance Risk Management (CRM) strategy.

CRM was first adopted by the Australian Taxation Organisation (ATO), then by the European Commission and was recently adopted as best practice by the OECD. It involves segmenting taxpayers to enable resources to be most effectively allocated toward ensuring the monitoring and compliance of the highest risk taxpayers, such as MNEs engaging in complex transfer pricing. Where resources are limited, as in developing countries, CRM is even more important, to ensure the most efficient revenue collection.[64] To implement CRM, developing countries need external investment in technology in order for data collection, storage and effective monitoring. This investment must include electronic invoicing and accounting, which will allow cheap and timely audit software validation, the identification of high risk tax payers and compliance control systems which will enable customer segmentation.[65]

Increase data collection and reporting on BEPS practices in developing countries.

Increasing monitoring and reporting of the tax practices of MNEs in developing countries will increase transparency and increase the reputational risks of companies engaging in these practices. The severity of these risks has been demonstrated in the developed world by some of the largest companies including Google, Starbucks and Amazon.  In the developed world, public pressure has impacted corporate tax policies.  In 2010, for example, Vodafone was forced to close UK stores due to people protesting their aggressive tax minimisation strategies, which resulted in them paying zero corporate tax on £400 million in UK sales. Vodafone responded by voluntarily making a tax payment, despite admitting it had done nothing illegal,[66] demonstrating the impact public opinion and reputation risk has on the actions of MNEs. Furthermore, studies have found that aggressive corporate tax strategies diminish corporate success through a lower willingness to pay, a cost that increases as media interest in taxation increases.[67]

Weak tax systems often mean that reliable, timely data and reporting is not available.  The IMF and World Bank can therefore play a crucial role in shedding light on the scale and negative impacts of corporate tax avoidance on developing countries. Increasing transparency and providing information which can be used to by governments, non-government organisations (NGOs) and individuals to place public pressure and reputational risk on companies engaging in these practices will deliver the most effective outcomes for developing countries.

Deloitte found that 80% of MNE staff surveyed agreed that their organisation is concerned about the increased media, political and activist group interest in corporate taxation and 74% agreed that reputational risks are of much greater concern when planning cross-border tax,[68] highlighting the potential effectiveness of this recommendation.

These first two recommendations also align with the UN’s goal to empower citizens through a ‘data revolution for sustainable development’. This goals seeks to improve the quality of statistics and information available to both governments and citizens to monitor progress towards the SDGs.[69] The World Bank and IMF can make a substantial contribution to the body of independent and rigorous monitoring necessary to ensure governments and multilateral organisations are accountable for development goals, including improving corporate taxation collection.

Ensure that efforts are coordinated with BEPS project, rather than overlapping to maximise the effectiveness of allocated resources.

The World Bank and IMF must ensure that the tools available to developing countries to improve their domestic tax systems do not overlap with the tools that are already being provided by the OECD and to ensure that funding and resources are not wasted and complexity is minimised. It may be necessary for the OECD, World Bank and the IMF to establish joint committee to ensure a collaborative effort in this area.

Conclusion

The global nature of corporate tax avoidance makes the MOs such as the G20, OECD, IMF and World Bank forums through which cooperation can lead to a global solution to BEPS.  Reducing the occurrence of BEPS outflows in developing countries has the potential to contribute to the achievement of SDGs and eradicate extreme poverty. Despite efforts to champion the interests of developing countries in the OECD BEPS Project, the way voting rights in IOs are assigned and the ineffectiveness of tax administrative systems in developing countries ensures the BEPS project will likely be more beneficial to developed countries than developing countries. Arguably, transparency is the key to obtaining the best outcomes for developing countries.  The IMF and World Bank should focus their efforts on strengthening tax systems in developing world.  There should also be increasing data collection and reporting of CTA practices in these countries.  This information can then be utilised by MOs and developed countries, such as Australia to increase public pressure on companies to engage in socially responsible tax practices. The World Bank and IMF should also establish a joint committee with the OECD to ensure a collaborative effort that minimises overlap and unnecessary complexity.

Footnotes

[1] International Monetary Fund, ‘IMF Policy Paper: Spillovers In International Corporate Taxation’, 9 May 2014, https://www.imf.org/external/np/pp/eng/2014/050914.pdf, (accessed 2 August 2015).

[2] Oxfam International, ‘Annual income of richest 100 people enough to end global poverty four times over’, 2013, Available from: https://www.oxfam.org/en/pressroom/pressreleases/2013-01-19/annual-income-richest-100-people-enough-end-global-poverty-four, (accessed 12 September 2015).

[3] G20, ‘G20 Leaders’ Declaration’, 2013, Available from: https://g20.org/wp-content/uploads/2014/12/Saint_Petersburg_Declaration_ENG_0.pdf, (accessed 28 September 2015).

[4] United Nations Department of Economic and Social Affairs (UNDESA), ‘SD in Action – Special Report on Voluntary Multi-Stakeholder Partnerships and Commitments for Sustainable Development’, 2015, Available from: https://sustainabledevelopment.un.org/sdinaction/2015report, (accessed 13 September 2015).

[5] The World Bank, ‘Financing the Post-2015 Development Agenda’, 2015, Available from: http://www.worldbank.org/mdgs/post2015.html, (accessed 13 September 2015).

[6] Institute for Development Studies, ‘Building Tax Capacity in Developing Countries’, 2015, Available from: http://opendocs.ids.ac.uk/opendocs/bitstream/handle/123456789/6522/PB96.pdf?sequence=3, (accessed 10 September 2015).

[7] OECD, ‘Developing countries to play greater role in OECD/G20 efforts to curb corporate tax avoidance’, 2014, Available from: http://www.oecd.org/g20/topics/taxation/developing-countries-toplay-greater-role-in-oecdg20-efforts-to-curb-corporate-tax-avoidance.htm, (Accessed 1 September 2015).

[8] Ockenden, W., ‘Apple pays $193m tax in Australia on $27b revenue as Federal Government vows to capture lost taxes’, ABC News, 2014, Available from: http://www.abc.net.au/news/2014-03-06/tax-expert-explains-how-apple-pays-193m-tax-on-27b-revenue/5303426, (Accessed 26 September 2015).

[9] Ibid.

[10] Love, P., ‘BEPS: why you’re taxed more than a multinational’, OECD Insights, 2013, Available from: http://oecdinsights.org/2013/02/13/beps-why-youre-taxed-more-than-a-multinational/, (accessed 10 September 2015).

[11] Sikka, P., ‘Corporate social responsibility and tax avoidance’, Accounting Forum, vol. 23, 2010, pp153-168, Available from: Science Direct, (Accessed 28 August 2015).

[12] UN Conference for Trade and Development, ‘World Investment Report 2015’, 2015, Available from: http://unctad.org/en/PublicationsLibrary/wir2015_en.pdf, (accessed 6 September 2015).

[13] International Monetary Fund, ‘IMF Policy Paper: Spillovers In International Corporate Taxation’, 9 May 2014, https://www.imf.org/external/np/pp/eng/2014/050914.pdf, (accessed 2 August 2015).

[14] Abromovsky, L. et al., ‘Corporate Tax in Developing Countries: Current Trends and Design Issues’, The Journal of Applied Public Economics, vol. 35, no. 4, 2014, pp. 559-588, Available from Wiley Online, (accessed 1 September 2015).

[15] Ibid.

[16] OECD, ‘Part 1 of a Report to G20 Development Working Group on the Impact of BEPS in Low Income Countries’, 2014, Available from: http://www.oecd.org/tax/tax-global/part-1-of-report-to-g20-dwg-on-the-impact-of-beps-in-low-income-countries.pdf, (accessed 5 September 2015).

[17] Terkper, S. ‘Tax, development and the new Millenium Development Goals’, International Tax Review, vol. 25, no. 1, 2014, Available from Business Source Premier, (accessed 25 August 2015).

[18] De Paepe, G. and Dickinson, B., ‘Tax revenues as a motor for sustainable development’, Organisation for Economic Cooperation and Development, 2014, Available from: http://www.oecd-ilibrary.org/docserver/download/4314031ec011.pdf?expires=1443256985&id=id&accname=guest&checksum=E523043EFAEFC04B717E9B9CC7C20226, (Accessed 26 September 2015).

[19] Kituyi, M., ‘5 Ways to Make the Taxation of Multinationals Fairer’, United Nations, 2015, Available from: http://www.un.org/esa/ffd/ffd3/blog/5-ways-taxation-of-multinationals-fairer.html, (accessed 3 September 2015).

[20] Ibid.

[21] OECD, ‘Net Development Assistance From DAC and Other Donors in 2013’, 2013, Available from: http://www.oecd.org/dac/stats/documentupload/ODA%202013%20Tables%20and%20Charts%20En.pdf, (accessed 8 September 2015).

[22] Waris, A., Kohnen, M., ‘Linking Taxation to the Realisation of the Millennium Goals in Africa’, 2011, available from: http://eadi.org/gc2011/waris-109.pdf, (Accessed 1 September 2015).

[23] UN Conference for Trade and Development, ‘World Investment Report 2015’, 2015, Available from: http://unctad.org/en/PublicationsLibrary/wir2015_en.pdf, (accessed 6 September 2015).

[24] Abromovsky, L. et al., ‘Corporate Tax in Developing Countries: Current Trends and Design Issues’, The Journal of Applied Public Economics, vol. 35, no. 4, 2014, pp. 559-588, Available from Wiley Online, (accessed 1 September 2015).

[25] Ibid.

[26] OECD, ‘Net Development Assistance From DAC and Other Donors in 2013’, 2013, Available from: http://www.oecd.org/dac/stats/documentupload/ODA%202013%20Tables%20and%20Charts%20En.pdf, (accessed 8 September 2015).

[27] Abromovsky, L. et al., ‘Corporate Tax in Developing Countries: Current Trends and Design Issues’, The Journal of Applied Public Economics, vol. 35, no. 4, 2014, pp. 559-588, Available from Wiley Online, (accessed 1 September 2015).

[28] International Monetary Fund, ‘Current Challenges in Revenue Mobilisation: Improving Tax Compliance’, 2015, Available from: https://www.imf.org/external/np/pp/eng/2015/020215a.pdf, (accessed 6 September 2015).

[29] Ibid.

[30] Ibid.

[31] Abromovsky, L. et al., ‘Corporate Tax in Developing Countries: Current Trends and Design Issues’, The Journal of Applied Public Economics, vol. 35, no. 4, 2014, pp. 559-588, Available from Wiley Online, (accessed 1 September 2015).

[32] Ibid.

[33] Devereux, M. P. and Vella, J., ‘Are We Heading Towards a Corporate Tax System Fit for the 21st Century?’, Institute for Fiscal Studies, vol. 35, no. 4, 2014, pp 44 – 475, Available from Wiley Online, (accessed 7 September 2015).

[34] Ibid.

[35] Ibid.

[36] Ibid.

[37] International Monetary Fund, ‘IMF Members’ Quotas and Voting Power, and the IMF Board of Governors’, 2015, Available from: https://www.imf.org/external/np/sec/memdir/members.aspx#U, accessed 5 September 2015).

[38] OECD, ‘Budget’, 2015, Available from: http://www.oecd.org/about/budget/, (accessed 5 September 2015).

[39] PWC, ‘Global Top 100 Companies by Market Capitalisation’, 2015, Available from: https://www.pwc.com/gx/en/audit-services/capital-market/publications/assets/document/pwc-global-top-100-march-update.pdf, (Accessed 15 September 2015).

[40] G20 Development Working Group, ‘About group’, 2015, Available from: http://www.g20dwg.org/, (accessed 28 September 2015)

[41] Plowgian, M., ‘BEPS: The Shifting International Tax Landscape and What Companies Should be Doing Now’, Tax Executive, vol. 65, no. 4, 2013, pp. 255-261, Available from EBSCOhost, (accessed 26 August 2015).

[42] G20, ‘About G20’, 2015, Available from: https://g20.org/about-g20/, (accessed 20 August 2015).

[43] Plowgian, M., ‘BEPS: The Shifting International Tax Landscape and What Companies Should be Doing Now’, Tax Executive, vol. 65, no. 4, 2013, pp. 255-261, Available from EBSCOhost, (accessed 26 August 2015).

[44] OECD, ‘OECD/G20 Base Erosion and Profit Shifting Project: 2014 Deliverables’, Available from: http://www.oecd.org/ctp/beps-2014-deliverables-executive-summaries.pdf, (accessed 28 September 2015).

[45] Devereux, M. P. and Vella, J., ‘Are We Heading Towards a Corporate Tax System Fit for the 21st Century?’, Institute for Fiscal Studies, vol. 35, no. 4, 2014, pp 44 – 475, Available from Wiley Online, (accessed 7 September 2015).

[46] Press, R. ‘Developing nations lose $100bn in tax revenue each year – will G20 reforms help?’, The Guardian, 2014, Available from: http://www.theguardian.com/sustainable-business/2014/nov/03/developing-nations-lose-100bn-tax-revenue-g20-reforms-avoidance, (Accessed 26 September 2014).

[47] Ibid.

[48] OECD, ‘Developing countries to play greater role in OECD/G20 efforts to curb corporate tax avoidance’, Available from: http://www.oecd.org/g20/topics/taxation/developing-countries-toplay-greater-role-in-oecdg20-efforts-to-curb-corporate-tax-avoidance.htm, (accessed 1 September 2015).

[49] Ibid.

[50] Ibid.

[51] Press, R. ‘Developing nations lose $100bn in tax revenue each year – will G20 reforms help?’, The Guardian, 2014, Available from: http://www.theguardian.com/sustainable-business/2014/nov/03/developing-nations-lose-100bn-tax-revenue-g20-reforms-avoidance, (Accessed 26 September 2014).

[52] Ibid.

[53] Ibid.

[54] Ibid.

[55] KPMG, ‘G20-OECD BEPS Action Plan: Taking the Pulse in the Asia Pacific Region’, 2015, Available from: https://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/Documents/g20-oecd-beps-aspac.pdf, (accessed 2 September 2015).

[56] United Nations Development Program, ‘International Human Development Indicators’, 2015, Available from: http://hdr.undp.org/en/countries, (accessed 4 September 2015).

[57] Deloitte US, ‘OECD’s Base Erosion and Profit Shifting (BEPS) initiative: Full results for second annual multinational survey’, 2015, Available from: http://www2.deloitte.com/content/dam/Deloitte/global/Documents/Tax/dttl-tax-beps-full-survey-results-may-2015.pdf, (accessed 10 September 2015).

[58] Ho, D. and Lau, P. ‘A Tax Study of Transfer Pricing In China’, International Tax Journal, vol. 28, no. 4, 2002, p62-78, Available from EBSCOhost, (accessed 5 September 2015).

[59] International Monetary Fund Fiscal Affairs Department, ‘Revenue Mobalisation in Developing Countries’, 2011, Available from https://www.imf.org/external/np/pp/eng/2011/030811.pdf, (accessed 21 August 2015).

[60] International Monetary Fund, ‘IMF Policy Paper: Spillovers In International Corporate Taxation’, 9 May 2014, https://www.imf.org/external/np/pp/eng/2014/050914.pdf, (accessed 2 August 2015).

[61] The World Bank Group, ‘Financing for Development Post-2015’, 2013, Available from: https://www.worldbank.org/content/dam/Worldbank/document/Poverty%20documents/WB-PREM%20financing-for-development-pub-10-11-13web.pdf, (accessed 3 September 2015).

[62] International Monetary Fund, ‘World Bank and IMF Launch Joint Initiative to Support Developing Countries in Strengthening Tax Systems’, http://www.imf.org/external/np/sec/pr/2015/pr15330.htm, 2015, (accessed 25 August 2015).

[63] Stephenson, M. ‘Economic Development and the Quality of Legal Institutions’, The World Bank, 2005, Available from: http://web.worldbank.org/WBSITE/EXTERNAL/TOPICS/EXTLAWJUSTINST/0,,contentMDK:23103355~menuPK:1989584~pagePK:210058~piPK:210062~theSitePK:1974062~isCURL:Y,00.html, (accessed 2 September 2015).

[64] International Monetary Fund, ‘Current Challenges in Revenue Mobilisation: Improving Tax Compliance’, 2015, Available from: https://www.imf.org/external/np/pp/eng/2015/020215a.pdf, (accessed 6 September 2015).

[65] Ibid.

[66] Barford, V. and Holt, G., ‘Google, Amazon, Starbucks: The rise of ‘tax chaming’’, BBC News, 2013, Available from: http://www.bbc.com/news/magazine-20560359, (Accessed 7 September 2015).

[67] Hardeck, I. and Hertl, R., ‘Consumer Reactions to Corporate Tax Strategies: Effects on Corporate Reputation and Purchasing Behavior’, Journal of Business Ethics, vol. 123, no. 2, 2014, pp. 30-326, Available from ProQuest, (accessed 23 August 2015).

[68] Deloitte US, ‘OECD’s Base Erosion and Profit Shifting (BEPS) initiative: Full results for second annual multinational survey’, 2015, Available from: http://www2.deloitte.com/content/dam/Deloitte/global/Documents/Tax/dttl-tax-beps-full-survey-results-may-2015.pdf, (accessed 10 September 2015).

[69] United Nations, ‘A New Global Partnership: Eradicate Poverty and Transform Economics Through Sustainable Development’, 2013, Available from: http://www.post2015hlp.org/wp-content/uploads/2013/05/UN-Report.pdf, (Accessed 26 September 2015).

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