19 Jan

Response from: Oxfam GB

Oxfam welcomes the creation of the All Party Parliamentary Group on Responsible Taxation (APPGRT) to build and maintain a fair and transparent tax system. We look forward to working closely with the group as it undertakes its work.

Given that it is estimated that countries around the world are losing up to $240 billion a year to corporate tax dodging,[1] it is vital that the UK Government takes action at the national and international level to ensure that multinational enterprises (MNEs) pay their fair share of tax. This tax revenue is vital to tackling poverty and inequality, through funding essential public goods such as healthcare, education and other services and infrastructure, both at home and abroad.

The following is Oxfam’s response to the APPGRT consultation on the OECD’s Base Erosion and Profit Shifting (BEPS) recommendations to the G20. The main areas it covers are:

  • Why it is vital to tackle base erosion and profit shifting to ensure sustainable financing for developing countries;
  • An overview of the OECD’s BEPS recommendations and their likely impacts;
  • The limitations of the BEPS outcomes;
  • The impact of the OECD BEPS process on developing countries and their involvement in the process;
  • Implementation of the BEPS action plan;
  • Moving beyond BEPS to a second generation of global tax reform;
  • Principles which could be considered over time as effective mechanisms for dealing with the changing global economy;
  • Actions the UK Government can take unilaterally to make corporations and wealthy individuals pay their fair share.

This response draws heavily on both the BEPS Monitoring Group[2] and Independent Commission for the reform of International Corporate Taxation (ICRICT)[3] evaluations of the BEPS process, and we recommend that these documents are reviewed for more in-depth analysis of the BEPS action plan.

In summary, Oxfam recognises the efforts made over the past two years to deliver the BEPS action plan.  It is a first step towards reforming the global tax system. However, many of the recommendations in the BEPS action plan are too weak and some critical issues are not addressed, as explained in further detail below. The BEPS process must mark the beginning – not the end – of global corporate tax reform. The 90-year-old international tax system is not fit for purpose in the 21st century, and we need more fundamental reform of broken global corporate tax system to ensure that all countries, especially developing countries, are able to claim their fair share of tax from MNEs.

Why base erosion and profit shifting is a problem, especially for developing countries

Corporate tax dodging fuels poverty and inequality by depriving governments of billions in revenues that could fund vital public services, such as free healthcare and education[4], and be invested in other important public functions such as law enforcement and infrastructure. While this is an issue that affects all countries, developing countries are hardest hit. It is estimated that developing countries lose at least $100 billion every year due to tax dodging by MNEs.[5]

In 2013, former UN Secretary-General Kofi Annan said that, for richer nations “if a company avoids tax or transfers the money to offshore accounts what they lose is revenues; here on our continent, it affects the life of women and children – in effect in some situations it is like taking food off the table for the poor”. Corporate income tax is enormously important to developing countries. It comprises a significant share of total tax receipts – around 18 percent – in low-income and lower middle-income countries.[6] More frequently promoted sources of tax revenue, such as value-added-tax (VAT), are often more regressive and therefore would increase inequality. Increasing revenues from personal income tax collection, even using a progressive approach to taxation, is still challenging because tax administrations are often too under-resourced to collect from a more diverse tax base. Examples of corporate tax dodging and its impact can be found on every continent. The problem for African countries is enormous. According to the Africa Progress Panel, an average of $38.4bn was lost to African countries annually through trade mispricing between 2008 and 2010, representing billions of dollars in lost tax revenues.[7] In Bangladesh, each year the government loses around $310m in tax revenues. An audit by Peru’s tax administration of only 27 cases of transfer pricing in 2013 revealed undeclared earnings of $350m, representing evaded taxes estimated at $105m.

These examples evidence why tackling corporate tax dodging is essential to give developing countries a fair chance of tackling poverty and inequality. Tax revenues will be essential to finance the recently agreed sustainable development goals (SDGs) to eradicate extreme poverty, which the UK government is committed to, and so it is vital that it does everything it can to ensure that developing countries are able to collect their fair share of tax revenues from MNEs.

The BEPS recommendations

While Oxfam recognises the efforts made to deliver the BEPS action plan, the agreed measures either fail to address, or only weakly address, many issues of critical importance to developing countries. BEPS does not go far enough to address the root problems of the global corporate tax system. The G20 mandate for the BEPS project was that international tax rules should be reformed to ensure that MNEs could be taxed ‘where economic activities take place and value is created’. This implied a new approach, to treat the corporate group of a MNE as a single firm, and ensure that its tax base is attributed according to its real activities in each country. Unfortunately, the BEPS project has continued to emphasise the independent entity principle, which starts from the fictitious assumption that affiliates of a corporate group act like separate legal persons, while attempting to counteract its harmful consequences. As a result, the BEPS outputs offer proposals to patch up existing rules, in many cases making them even more contradictory and complex, and fail to provide a coherent and comprehensive set of reforms. These weaknesses are addressed further later in this paper.

Country-by-country reporting

There aae, however, some positives of the BEPS recommendations. For the first time, tax authorities will (potentially) have information on MNEs’ activities worldwide. The Country-by-Country Reporting template of information on global operations and profits by country of MNEs has been created under Action 13, which will require reporting of company revenues, profits, taxes paid, employees and assets in each country where they do business. While the template is welcome, country-by-country reporting (CBCR) to tax authorities will never be a replacement for openly publishing CBCR information. It is vital that CBCR information is made public so that developing countries can access the data, and citizens and civil society can hold corporations to account for their tax practices. Many developing countries will be unable to access the BEPS CBCR data as they do not meet the confidentiality requirements, and do not have information exchange agreements in place with residence countries.[8]

Furthermore, the threshold for compliance with CBCR requirements in the BEPS recommendations is set too high. The current draft UK legislation implementing Action 13, which follows the BEPS recommendations, outlines that CBCR requirements will apply only to MNEs that have a total consolidated group revenue of £586 million or more, which will effectively exclude the vast majority of MNEs from the reporting requirements. To put the threshold into context, it is higher than the entire GDP of the Gambia.[9] It has been shown that the BEPS recommended threshold would lead to many MNEs being excluded from CBCR legislation. For example, this high threshold would mean that only 262 listed companies in the UK would be required to comply with CBCR regulations out of over 2,000.[10] While this figure is illustrative as it does not include non-listed companies, it is clearly indicative of the fact that the high threshold will ensure that many UK-based MNEs will not be required to comply with the legislation. According to the OECD’s own estimates, this threshold means excluding 85-90% of all the world’s MNEs.[11]

The BEPS recommendation on CBCR also has the risk of undermining ongoing efforts at a European level to introduce public CBCR for all companies. The little country-by-country information which has been released to the public has proven to contain important information. For example, the country-by-country report released by Barclays in 2014, under the Capital Requirements Directive, showed that although the bank had only 14 employees in Luxembourg it generated £1.4 billion of profits there in 2013 – £100 million per employee.[12] The report released in 2015 indicates that the reporting requirement may have had an impact on the bank’s tax planning as the report shows that Barclays increased its number of employees in Luxembourg, lowered the amounts of profits generated there and increased its tax payments in the UK.[13] Furthermore, a year ago, the European Commission and PricewaterhouseCoopers conducted an impact assessment of public CBCR for the European financial sector. The conclusion was that disclosing CBCR information “was unlikely to have a significant negative economic impact, and could have a small positive economic impact”[14]. Public CBCR is vital so that governments and civil society in rich and poor countries alike can scrutinise the tax behaviour of MNEs. The UK Government should support public CBCR at both the national and European level.

Multilateral instrument

There were two welcome revisions to bilateral tax treaties, which will be available to implement via the multilateral agreement for BEPS tax treaty measures.[15] One of these proposals is a standard treaty abuse clause to prevent tax avoidance by routing income through conduit countries which are part of a treaty network. Known as a ‘primary purpose test’, this treaty provision provides more legal authority for countries to evaluate the economic substance of income attribution and challenge the characterisation of transactions that have the primary purpose of avoiding taxation. Secondly, a revision of the ‘permanent establishment’ or tax nexus rules could expand source countries’ ability to tax economic activity occurring through commissionaire (an independent entity acting on behalf of an MNE)  arrangements within their borders. This expanded tax nexus rule represents a modest but welcomed advance in shifting more taxing power to countries where economic activities take place.

The multilateral instrument is also welcome as it will save valuable tax administration resources—which are scarce in all countries, but particularly low-income countries—because all of a country’s individual bilateral agreements can be amended at once, provided that these treaty partners are also signatories to the multilateral agreement.

Limitations of BEPS

However, while these areas of progress are welcome, on the whole the BEPS outcomes are weak and will not ensure that MNEs are taxed where they really make their profits. Key issues to note are as follows:

  • BEPS will not ensure MNEs pay tax where they do business.
  • BEPS will not reduce the use of tax havens, which is important as tax havens are at the heart of the rigged global tax system that enables wealthy individuals and MNEs to avoid paying their fair share.
  • BEPS will not stop the race to the bottom where countries offer increasingly generous tax incentives to attract investment. Between 2005 and 2010 mining companies in Colombia paid US$456 million per year in income tax, but received tax discounts, deductions and exemptions worth US$925 million. For every dollar that they paid in taxes, the state did not collect two[16].
  • BEPS does not address tax avoidance in sectors that are important in developing countries, such as the extractives industry.
  • As noted, BEPS will not require MNEs to produce public reports on activities for each country in which they operate – this information will only be accessible by tax authorities, These reports, which include a breakdown of their employees, physical assets, sales, profits, and taxes (due and paid) will help governments make an accurate assessment of whether companies were paying their fair share of taxes but citizens, consumers and shareholders deserve the right to have access to this information too. Furthermore, many developing countries will not be able to access this information.

The outcomes of BEPS are clearly only a start. Implementation by states will take time and should be monitored, and key issues remain to be dealt with. The following sets out in further detail the shortcomings of the BEPS measures. For more information please refer to BEPS Monitoring Group evaluation report.[17]

Tax treaties

The aim of tax treaties has too long been regarded as only the prevention of double taxation, disregarding the equally important purpose of ensuring appropriate taxation, which should be an explicit provision in all treaties. Inclusion of an anti-abuse rule is proposed in the BEPS recommendations, which should at least include a standard principal purpose test. To be effective, this will need systematic information exchange to verify the tax status of recipients, as will the proposals for dealing with treaty abuses by using hybrid entities or instruments through complex rules for denying deductions. Abuse of the separate entity principle by fragmenting functions will be only partially dealt with by the proposal to deem that an entity has a permanent establishment (taxable presence) in limited circumstances, if activities can be said to be ‘preparatory or auxiliary’ to sales. This very limited approach allows firms to continue to fragment non-sales-related functions and attribute higher profits to countries where they will be lightly taxed.

Transfer pricing

The continued reliance on the separate entity fiction has also led to increased complexity of rules on transfer pricing, to allow tax authorities to re-characterise transactions between related parties, but only following a detailed and ad hoc ‘facts and circumstances’ analysis and searches for ‘comparables’. This subjective and discretionary approach will increase enforcement and compliance costs and generate conflicts. Recognising this, and responding to business concerns, it is proposed to strengthen dispute resolution procedures, including an increased use of arbitration. However, it is inappropriate and illegitimate to seek to remedy the failure to agree clear rules by providing procedures conducted in complete secrecy to deal with the inevitable disagreements in their application.

Attribution of profit

The main shortcoming is the failure to develop clear rules for the attribution of profit. Further work is planned on the profit split method, which could provide a way forward. The report on digitalisation of the economy recognises that it raises key issues going beyond the BEPS project, including the basic concepts of residence and source, and where profit should be considered to be earned. Although the BEPS project itself can only be said to have been a partial success, it has succeeded in opening space for more far-reaching changes. It should be seen as part of a longer process, which should aim at finally reforming international tax rules to ensure fairness for all, especially developing countries, and make them fit for the 21st century.

National concerns

Regrettably also, several of the initially sensible proposals have been greatly weakened by the insistence of some powerful OECD states on preserving their preferred tax breaks for business, generally in the name of national ‘competitiveness’. This has resulted, for example, in weak proposals on Controlled Foreign Corporations (CFCs), interest deductibility and innovation box schemes, all favoured particularly by the UK. Meanwhile, other countries, especially the United States, have stubbornly defended the dysfunctional arm’s length principle for transfer pricing adjustments, and resisted alternatives. Hence, despite the best efforts of OECD officials themselves to try to achieve a strong package, the lack of a clear direction, national political concerns to preserve tax breaks considered to benefit national ‘competitiveness’, and the need for consensus among a large group of countries, have led to a package tending to the lowest common denominator.

The result is that the proposals will make international tax rules even more complex, and largely retain the scope for countries to offer tax breaks, while raising compliance costs for MNEs, yet preserving the systemic incentives for them to devise avoidance structures. The consequence of weak coordination will be an acceleration of unilateral measures: some have already been initiated by countries such as the UK and Australia, and other countries are likely to follow, to protect their tax base.[18]

Other shortcomings reflect a lack of political will. Despite the enormous size and urgency of the BEPS problem, some OECD countries let their national preferences prevail over the need for global reform. One example is the weak compromise to phase out harmful innovation box regimes, which are allowed to remain in place until 2021. Another example is the failure to agree anti-abuse rules – such as rules for Controlled Foreign Companies (CFC) – in the home countries of MNEs. Such rules could deter profit shifting to tax havens, reducing tax avoidance in host developing countries as well.

Impact of the BEPS recommendations on developing countries and their involvement in the process

Two-thirds of the world’s governments had no formal role and no real say in the BEPS process – as a result many of their concerns are not addressed by the action plan. Despite the OECD and G20’s inclusion of a select group of additional countries and regional tax administration networks during the last phase, such arrangements did not constitute truly inclusive global tax policy making.  Moreover, those countries joined in the middle of the negotiations without having an opportunity to contribute to defining the negotiating agenda. As invitees, they were given a voice, but not a vote in the decision-making. The regional consultations that took place, while appreciated, were a poor substitute for an equal say in the negotiations. Unfortunately, the contributions made at the regional consultations do not seem to have been effectively represented in the final BEPS deliverables, leading to many key issues for developing countries being insufficiently addressed, as is explained below.

The OECD is only considering an active role for developing countries in the implementation phase, starting in 2016. This would mean developing countries can more fully participate in discussions on how to implement decisions made by others. The BEPS package has not been designed with the interests of developing countries front and centre, so implementation of the outcomes will be of limited benefit to them. Moreover, opposition from the corporate lobby and some developed countries narrowed the scope of reform leaving many key tax loopholes unaddressed. The corporate lobby had excessive influence in the process – for example when the OECD opened consultation on new draft rules at the end of 2013 almost 87 percent of the contributions came from the business sector.[19]

As a consequence of developing countries, on the whole, being excluded from the BEPS process, some issues of key importance to developing countries, such as the balance of taxing rights (taxing at source versus country of residence) or tax avoidance on the capital gains from selling businesses to other MNEs, are not included in the action plan. Furthermore, the proposed methods to prevent MNEs from manipulating the prices of internal transactions are unworkable for smaller developing countries because they require data that do not exist in such jurisdictions. Other issues of key importance to developing countries, such as harmful tax practices, unproductive tax incentives and taxing commodities, are not well covered by BEPS.

At the recent UN Financing for Development Conference in Addis Ababa, developing countries were resolute in their call for equal participation in negotiations of global tax reform. The G20 cannot ignore this legitimate demand from a negotiating bloc that includes over two thirds of the world’s governments. The UK must push the G20 and other international institutions to build on the progress made so far and renew its commitment to effectively put an end to harmful corporate tax practices, in a way that benefits all countries, including all developing countries.

Implementation of the BEPS action plan

Considering the flaws of the BEPS process and outcomes, the OECD cannot yet say it has closed all tax loopholes and put an end to aggressive tax planning by MNEs. The focus cannot exclusively be on implementation and capacity building for developing countries: much more is needed. Implementation of BEPS must not come at the expense of also making progress on the issues not dealt with by BEPS, and addressing some of the governance gaps in the current global tax system.

Implementation of the BEPS action plan is not incompatible with a second generation of global tax reforms that could put on the agenda key issues that matter to developing countries and as part of a more inclusive process. If the international community is serious about putting an end to all corporate tax abuses, implementation efforts have to be driven in parallel with a new broader global agenda.

Focusing on delivering capacity-building programmes (though necessary) and/or ensuring developing countries will be able to implement BEPS will not be sufficient and will not guarantee that global taxation rules are changed in their interests. They will remain hampered by a system that still facilitates tax dodging by MNEs that favours countries where these companies are resident and that encourages poor countries to give generous tax breaks and tax rates to attract foreign investment.

Capacity building programmes should provide the opportunity to not only implement decisions made by others but also to enable developing countries to participate on an equal footing in all decision-making processes. Relevant international organisations and donor countries need to commit to a long-term coordinated capacity building programme to strengthen tax systems and administrations in developing countries with this in mind. Those non-OECD/G20 countries choosing to implement BEPS should be supported with technical expertise as well as adequate tools to conduct impact assessments following a period of implementation. Given the fact, as stated in the report under Action 11, that there is a lack of suitable data to quantify the extent of BEPS and to help track whether the reforms meet their stated objects, resources for non-OECD/G20 to assess the impact of BEPS after implementation are especially important. Crucially, governments must be supported in voicing any shortcomings in the BEPS reforms with a view to negotiate change.

Moving beyond BEPS to a second generation of global tax reform

It is now time for a more inclusive global initiative to build on the work started by the OECD, making the corporate tax system fit for the 21st century and work for the whole world, rather than negotiating patchwork solutions that serve vested interests in specific countries. Oxfam is calling on world leaders to support a second generation global tax reform process that include all countries on an equal footing, and which create an international tax system that works in the interest of the majority.

This second generation reform process should embrace all governments and all relevant international organisations (such as the IMF, World Bank, UN and OECD), allowing for a more legitimate and representative dialogue. Ultimately we need an independent global tax body that comprises all governments – including developing countries.

This second generation reform process should urgently tackle a number of key issues which have not been addressed or have been insufficiently addressed by the BEPS process.  These include:

  • Putting an end to the race to the bottom caused by competitive granting of tax incentives and lowering of tax rates, and tackling corporate tax havens;
  • Reallocating tax rights between countries, for example by revising tax treaty terms and so-called transfer pricing and permanent establishment rules;
  • Addressing avoidance of capital gains tax;
  • Stepping up work on the so-called profit split method to prevent manipulation of internal transaction prices and developing alternative methods, while exploring more fundamental long-term reforms.

Principles which could be considered over time as effective mechanisms for dealing with the changing global economy

In the long-term governments should explore adopting a system of unitary taxation for MNEs. This is recommended by ICRICT and would involve taxing MNEs as single firms by combining their global profits and then allowing each country where the corporation operates or sells goods to tax only the portion of profits attributable to the corporation’s economic activity there.

The defects of the current system are clearly spelt out in the ICRICT declaration[20], including its inherent inability to cope with a globalised, knowledge-based economy, and how it works to the disadvantage of all countries, especially poorer developing countries. MNEs should no longer be allowed to structure their business in multiple pockets around the globe that take advantage of low tax rates and accounting practices, which move money out of one pocket and into another through a simple stroke of a key. Although it is considered legal under the current rules this kind of manoeuvring affects the lives of real people as it drains public revenues that fund health care, law enforcement, education, infrastructure and other important public functions.

The main failing of the BEPS project is its inability to address the core problem of the global tax framework: the transfer pricing system. This system provides wide latitude for companies to move profits around the world to low tax jurisdictions, using mythical prices. And the problems have only been amplified with the growth of intellectual and other forms of “soft” capital. Using the transfer pricing system for the allocation of profits originating in the different U.S. states would be absurd, and so they collectively use a unitary taxation system. As globalisation proceeds, using the transfer pricing system across the different states of the world is equally absurd. Yet the OECD’s attempts to reduce tax avoidance and make improvements in a flawed system studiously avoid addressing these fundamental issues.

The G20 mandate implied a new approach, to treat the corporate group of a MNE as a single firm and attribute its tax base according to its real activities in each country. Unfortunately, the OECD process did not apply this but instead continued to emphasise the independent entity principle, while attempting to counteract its harmful consequences. Consequently the BEPS outputs fail to provide a coherent and comprehensive approach, and offer instead proposals for a patch-up of existing rules, making them even more contradictory and complex. Governments should explore alternative methods of taxing MNEs which treat them as single entities such as unitary taxation.

Actions the UK Government could take unilaterally

As noted above, it is essential that there is a second generation of global tax reform, including all countries, so that key issues that are not addressed by the BEPS process are addressed in an inclusive forum. However, there are several actions that the UK Government could take unilaterally to tackle tax dodging.

Firstly, the UK can take action to ensure its overseas territories and crown dependencies (OTs and CDs) – such as the British Virgin Islands and Jersey – introduce public registers of beneficial ownership. Opaque structures in these jurisdictions allow individuals and companies to hide vast amounts of taxable income offshore, especially from developing countries, and thus avoid paying tax. The UK Government showed leadership on the issue of registries by legislating for a public register of beneficial ownership for companies in the UK. However, it must commit to extending this register to covering foundations and trusts. In 2013 the government also asked the OTs and CDs to increase transparency of company ownership but none have yet introduced public registers. The UK Government needs to keep up pressure on these jurisdictions to introduce public registers so to shine a light on beneficial ownership not only in the UK but in the OTs and CDs as well.

Secondly, the government should commit to introduce public country-by-country reporting for all UK companies. Public disclosure is vital so that civil society and developing country governments have access to this information and can hold companies to account. In their 2015 election manifesto the Government promised to consider the case for making country-by-country reporting information publicly available.[21] Given recent evidence from the EU that public disclosure is unlikely to have a negative economic impact, and could in fact have a positive one, the UK should introduce public CBCR for all UK companies.[22] The recommendation for CBCR reports to be made available only to tax authorities is one of the major flaws of the BEPS process and the UK Government should support ongoing efforts at a European level to introduce public CBCR for all sectors.[23]

Thirdly, the government should use the power of its procurement contracts to incentivise more companies to adopt responsible tax practices. Companies gaining lucrative government contracts, paid for by the taxpayer, should be paying their fair share into the tax system. Standards like the Fair Tax Mark,[24] and those set out in the Getting to Good paper, jointly published by ActionAid, Christian Aid and Oxfam,[25] provide clear signposts for what responsible tax practices look like.  The Government can play a key role in incentivising more companies to meet these standards, encouraging a “race to the top” amongst companies.

Fourthly, the government should be taking more steps to understand the impact of its corporate tax rules on other countries and particularly on the poorest countries. The UK should undertake a rigorous and independent ‘spillover analysis’ of UK corporate tax rules to assess whether they have harmful knock on effects on the ability of developing countries to collect their own taxes.  This would include studying the impact of the UK’s tax treaty policy with respect to developing countries.[26] Recent studies from the Netherlands and Ireland have shown that this kind of analysis is possible.[27]

This response was submitted via email. You can view the original response here.

For further information please contact:

Claire Spoors, Policy Adviser, cspoors1@oxfam.org.uk

 

[1] OECD (2015), Measuring and Monitoring BEPS, Action 11 – 2015 Final Report, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris.
DOI: dx.doi.org/10.1787/9789264241343-en

[2] BEPS Monitoring Group (2015) Overall Evaluation of the G20/OECD Base Erosion and Profit Shifting (BEPS) Project, bepsmonitoringgroup.files.wordpress.com/2015/10/general-evaluation.pdf

[3] ICRICT (2015), Evaluation of the ICRICT for the BEPS Project of the G20 and OECD, www.icrict.org/wp-content/uploads/2015/10/ICRICT_BEPS-Briefing_EN_web-version-1.pdf

[4] Oxfam (2014) Working for the Many: Public Services Fight Inequality www.oxfam.org/en/research/working-many

[5] UNCTAD (2015), World Investment Report 2015unctad.org/en/PublicationsLibrary/wir2015_en.pdf

[6] 2 ActionAid (2013) ‘A level playing field? The need for non-G20 participation in the BEPS process’, www.actionaid.org.uk/sites/default/files/publications/beps_level_playing_field_.pdf

[7] L. Donnelly (2013) ‘Corruption, weak governance costing Africa billions’, Mail & Guardian, mg.co.za/article/2013-05-10-report-corruption-weak-governance-costing-africa-billions

[8] Cobham, A. (2015) OECD Country-by-Country Reporting: Only for the Strong? Uncounted Blog uncounted.org/2015/09/14/oecd-country-by-country-reporting-only-for-the-strong

[9] World Bank GDP Data (2014), GDP of the Gambia = US $807mn = £522mn databank.worldbank.org/data/download/GDP.pdf

[10] Eurodad (2015) 50 Shades of Tax Dodging: The EU’s Role in Supporting an Unjust Global Tax System, www.eurodad.org/files/pdf/56378e84d0fac.pdf

[11] OECD (2015), Action 13: Guidance on the Implementation of Transfer Pricing Documentation and Country-by-Country Reporting: www.oecd.org/ctp/beps-action-13-guidance-implementation-tp-documentation-cbc-reporting.pdf

[12] Barclays (2014), Country Snapshot 2013: www.home.barclays/content/dam/barclayspublic/docs/Citizenship/Reports-Publications/CountrySnapshot.pdf

[13] Barclays (2015), Country Snapshot 2014: www.home.barclays/content/dam/barclayspublic/docs/Citizenship/Reports-Publications/2014_country_snapshot.pdf

[14] PwC (2014), Study prepared by PwC for European Commission DG Markt following the contract 2014/S 102-177729. General assessment of potential economic consequences of country-by-country reporting under CRD IV

[15] OECD (2015) Multilateral instrument for BEPS tax treaty measures: the Ad hoc Group www.oecd.org/tax/treaties/multilateral-instrument-for-beps-tax-treaty-measures-the-ad-hoc-group.htm

[16] Garay, J. (2013) “Minería en Colombia””, Contraloría General de la República http://www.rebelion.org/docs/167838.pdf

[17] BEPS Monitoring Group (2015) Overall Evaluation of the G20/OECD Base Erosion and Profit Shifting (BEPS) Project, bepsmonitoringgroup.files.wordpress.com/2015/10/general-evaluation.pdf

[18] BEPS Monitoring Group (2015) Overall Evaluation of the G20/OECD Base Erosion and Profit Shifting (BEPS) Project, bepsmonitoringgroup.files.wordpress.com/2015/10/general-evaluation.pdf

[19] Oxfam (2014) Business Among Friends: Why Corporate Tax Dodgers are not yet Losing Sleep over Corporate tax reform www.oxfam.org/sites/www.oxfam.org/files/bp185-business-among-friends-corporate-tax-reform-120514-en_0.pdf

[20] ICRICT (2015) Declaration of the Independent Commission for the Reform of International Corporate Taxation  www.icrict.org/declaration

[21] The Conservative Party (2015), The Conservative Party Manifesto 2015 s3-eu-west-1.amazonaws.com/manifesto2015/ConservativeManifesto2015.pdf, p. 11

[22] PwC (2014), Study prepared by PwC for European Commission DG Markt following the contract 2014/S 102-177729. General assessment of potential economic consequences of country-by-country reporting under CRD IV ec.europa.eu/internal_market/company/docs/modern/141030-cbcr-report_en.pdf

[23]Eurodad (2015), European Parliament Sets the Stage for Europe to Embrace More Corporate Fiscal Transparency eurodad.org/Entries/view/1546446/2015/07/08/European-Parliament-sets-the-stage-for-Europe-to-embrace-more-corporate-fiscal-transparency

[24]Fair Tax Mark (2015), The Fair Tax Criteria www.fairtaxmark.net/criteria/

[25] Oxfam, Christian Aid, ActionAid (2015) Getting to Good: Towards Responsible Corporate Tax Behaviour policy-practice.oxfam.org.uk/publications/getting-to-good-towards-responsible-corporate-tax-behaviour-582243 

[26] Hearson, M. (2015), Some Follow-Up on Parliamentary Scrutiny of the UK–Senegal Treaty martinhearson.wordpress.com/2015/10/30/some-follow-up-on-parliamentary-scrutiny-of-the-uk-senegal-treaty

[27] Weyzig, F. (2015), Spillover Analysis of Irish Tax Policy francisweyzig.com/2015/10/14/spillover-analysis-of-irish-tax-policy

This response was submitted via email. You can read the full response here.