This update provides a snapshot of the publications and social media activities of the South Centre during the month of December 2018.
The Definition and Treatment of Tax Havens in Brazilian Tax Law between 1995 and 2015
Over the years, a number of ‘tax haven lists’ have been created at the national and international level, with varying definitions and criteria used to identify jurisdictions falling under their scope. This policy brief presents the experience of Brazil in compiling their national list of tax havens, the road map they followed for its implementation, and the impact that it has had on their foreign investment flows. It also provides the lessons learnt from this experience, which can be positively utilized by other developing countries.
This update provides a snapshot of the publications and social media activities of the South Centre during the month of November 2018.
Stemming ‘Commercial’ Illicit Financial Flows & Developing Country Innovations in the Global Tax Reform Agenda
Illicit Financial Flows generated due to the commercial activities of multinational enterprises are quantitatively the most important challenge faced by developing countries in achieving the Sustainable Development Goals. Current efforts for stemming these illicit flows and reforming the international tax system are however being led by developed countries, with developing country interests poorly reflected in the reform agenda. This research paper highlights the tax issues of great priority for developing countries and how international tax cooperation can contribute to preventing such illicit flows.
This update provides a snapshot of the publications and social media activities of the South Centre during the month of October 2018.
South Centre Quarterly Report, 1 July to 30 September 2018
This report summarizes the programmatic activities of the South Centre during the period 1 July to 30 September 2018. It is intended to provide information, organized by Program and themes, about recent developments in the areas covered by the South Centre’s Work Program and publications and meetings organized or co-organized by the Centre to examine particular issues or to provide analytical support for international negotiations taking place in various fora. It also informs about external conferences and other meetings where the Centre has participated.
This update provides a snapshot of the publications and social media activities of the South Centre during the month of September 2018.
Exchange of Information: Indian Experience, Developing Country Implications
Exchange of tax-related information between countries is a critical tool for addressing information asymmetries between governments and taxpayers that facilitate tax evasion/avoidance. However, the existing system of information exchange has been essentially designed and implemented by the OECD, without the participation of developing countries. This policy brief thus discusses India’s experience with implementing information exchange for tax and other purposes, with lessons being drawn for other developing countries grappling with base erosion and profit shifting.
This update provides a snapshot of the publications and social media activities of the South Centre during the month of August 2018.
Interaction of Transfer Pricing & Profit Attribution: Conceptual and Policy Issues for Developing Countries
Till 2010, model tax conventions treated profit attribution to permanent establishments and transfer pricing under different articles, and profit attribution under Article 7 allowed sales to be taken into account both in the direct accounting method as well as the indirect apportionment method. However, the revised Article 7 in the 2010 update of the OECD Convention approximated profit attribution with transfer pricing and omitted the option of apportionment, thereby undermining sales and contributions made by market jurisdiction to business profits. When a tax treaty retains Article 7 based on the UN Convention or the earlier OECD Convention, Contracting States can take sales into account and also opt for apportionment. Developing countries need to fully understand these implications of Article 7 in their tax treaties, and opt for informed choices for transfer pricing and profit attribution to permanent establishments, including apportionment that takes sales into account.
Second Annual Developing Country Forum for Cooperation in International Tax Matters, 25-27 April 2018
Title: Second Annual Developing Country Forum for Cooperation in International Tax Matters
Date: 25-27 April 2018
Venue: Yogyakarta, Indonesia
Organizers: The South Centre and the Ministry of Foreign Affairs of the Republic of Indonesia
Collaboration or Co-optation? A review of the Platform for Collaboration on Tax
The Platform for Collaboration on Tax (PCT), launched in April 2016, is an effort to intensify cooperation on tax issues among the staff of the OECD, IMF, World Bank and the United Nations. The PCT’s stated objectives include the production of joint outputs, strengthening interactions between standard setting, capacity building and technical assistance and sharing information. PCT has since produced toolkits on issues such as tax incentives, transfer pricing, and taxation of offshore indirect transfers. The PCT also held its first global conference in February 2018 at the UN where a concluding ‘conference statement’, negotiated among the four secretariats, was produced.