Is increased tax transparency leading to tax uncertainty?

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Globalisation has led to a significant proportion of international trade to be carried out by conglomerates or multi-national enterprises (MNEs) who operate across multiple countries through related parties. A January 2017 report by the Organisation for Economic Co-operation and Development (OECD) estimates that base erosion and profit shifting (BEPS) tools employed by MNEs are responsible for tax losses of approximately $100 billion to $240 billion per annum. Of late, the issue of MNEs paying their ‘fair share’ has been leading the public narrative and debated widely among various stakeholders including politicians and the general public.

In the aftermath of the leak of the ‘Paradise Papers’, 200 delegates met in Cameroon for the 10th meeting of the ‘Global Forum on Transparency and Exchange of Information for Tax Purposes’, which included 147 countries and jurisdictions. Thus, governments have come together under the OECD umbrella to

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