Base Erosion and Profit Shifting: A Blueprint for Africa’s Response
This book provides a thorough analysis of the implementation of the OECD/G20 BEPS measures in Africa and considers the experiences, challenges and opportunities for African countries.
Why This Book?
Increased globalization and technological enhancement have led to the integration of the global economy, allowing multinational enterprises to operate more efficiently. In most cases, this involves complex structures and may present challenges from a tax perspective due to gaps and mismatches in countries’ tax systems. A significant challenge is the risk of tax base erosion and profit shifting (BEPS).
The last few years have witnessed many coordinated initiatives in the international tax arena to identify and address the causes of BEPS. Various organizations have been at the forefront in this regard, including the OECD, UN, IMF and the World Bank Group (collectively constituting the Platform for Collaboration on Tax) and the African Tax Administration Forum (ATAF).
Base Erosion and Profit Shifting: A Blueprint for Africa’s Response discusses the relevance to Africa of the various measures proposed under the OECD project to tackle BEPS. It approaches the different topics from policy and practical perspectives that will be useful for all readers. It enriches both of these perspectives by setting out African countries’ experiences and challenges and discussing case law from the region. The book discusses the opportunities for Africa by proposing options to aid in implementing the BEPS measures. This book is the first comprehensive publication on international taxation in Africa.
This book is essential reading for policymakers, public and private tax practitioners, students and other stakeholders interested in African taxation matters. The author presents the information in an easy-to-understand manner that ensures that no reader is left behind. This work creates a platform that will stimulate further discussions within the region regarding the essential topics covered and broader tax issues for Africa.
Base Erosion and Profit Shifting: A Blueprint for Africa’s Response
DOI: https://doi.org/10.59403/2hx7z8b
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List of Contributors
DOI: https://doi.org/10.59403/2hx7z8b
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Acknowledgements
DOI: https://doi.org/10.59403/2hx7z8b
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Introduction
DOI: https://doi.org/10.59403/2hx7z8b
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Abbreviations
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 1: Domestic Resource Mobilization and Introductory Remarks on BEPS
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 2: Base Erosion and Profit Shifting in Africa
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 3: Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance – Action 5
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 4: Preventing Treaty Abuse – Action 6
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 5: Re-Examining Transfer Pricing Documentation – Action 13
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 6: Improving Dispute Resolution – Action 14
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 7: Neutralizing the Effects of Hybrid Mismatch Arrangements – Action 2
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 8: Designing Effective Controlled Foreign Company Rules – Action 3
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 9: Limiting Base Erosion Involving Interest Expenses and Other Financial Payments – Action 4
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 10: Mandatory Disclosure of Aggressive Tax Planning – Action 12
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 11: Preventing the Artificial Avoidance of Permanent Establishment Status – Action 7
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 12: Ensuring that Transfer Pricing Outcomes Are in Line with Value Creation – Actions 8-10
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 13: Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS – Action 15
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 14: Addressing the Tax Challenges Arising from the Digitalization of the Economy – Action 1 and Subsequent Work
DOI: https://doi.org/10.59403/2hx7z8b
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Chapter 15: Concluding Remarks
DOI: https://doi.org/10.59403/2hx7z8b
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Emily Muyaa
Ridha Hamzaoui, Sabrine Marsit, Yvette Nakibuule Wakabi, Abdoul Aziz Son
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