BRICS and the Emergence of International Tax Coordination - Review 1
BRICS and the Emergence of International Tax Coordination edited by Yariv Brauner and Pasquale Pistone, IBFD 2015
Reviewed by Christiana HJI Panayi, British Tax Review B.T.R. 2015, 2, 273-275.
economies in their quest for a voice in the governance of the international tax regime. It comprises of 18 chapters. The authors of the initial chapters in Part I engage in a theoretical discussion on the issues. Tsilly Dagan’s thought-provoking Chapter 2 provides an analysis of the theoretical framework and the potential for co-operation.3 She argues that co-operation is not necessarily good and its consequences are not always desirable. In so doing, Dagan refers to "cartelistic cooperation", a concept that she considered in her previous work.4 Her arguments seem to counter the conclusions of the base erosion and profit shifting (BEPS) initiative that a shift to co-operation is a prerequisite for the survival of the international tax regime. Whilst this may be to the benefit of OECD countries, it might not necessarily serve the BRICS countries. In the subsequent chapter, Reuven Avi-Yonah considers the supranational perspective of the current international tax regime.5 In line with his single tax principle, he sets out a list of suggested reforms based in part on BRICS practice.
emphasis on the relations with the UN are examined. The role of the BRICS countries in shaping the global political debate and international tax reform are also briefly considered. There is a very interesting contribution by Richard Vann, who reviews current trends in balancing residence and source taxation and the position of BRICS.7 The important role of the BRICS in recent tax work undertaken by the UN is examined by Alfredo Garcia Prats—more theoretically8 —and Jan de Goede at a technical level.9 The international tax policy directions of the BRICS countries are reviewed by Kim Brooks at a high level, based on the country reports.10 She finds the BRICS countries to have highly sophisticated tax systems which are very much in transition. Brooks concludes that with some co-ordination:
Finally, Diane Ring examines in more detail the impact of the BRICS countries and their tax policy themes on international tax organisations such as the OECD and the UN.12 The limitations of the BRICS countries in transforming the international tax landscape are considered but their great potential is recognised.
The editors, Yariv Brauner and Pasquale Pistone, conclude in the final chapter of the book.13
Overall, this book provides an excellent analysis of some of the important issues relating to the
BRICS and international tax reform. Whilst the BEPS project does not feature as prominently in the contributions as would have been the case had the book been finalised perhaps a year later, the wealth of materials and ideas is likely to prove very useful in the post-BEPS world. This book is highly recommended not only for international tax scholars but also for tax administrators.
Christiana HJI Panayi
https://www.law.umich.edu/centersandprograms/lawandeconomics/abstracts/2002/Documents/tsilly02-007.PDF [Accessed May 20, 2015]; T. Dagan, "Just Harmonization" (2010) 42 University of British Columbia Law Review 331.