Human Capital in Value Creation and Post-BEPS Tax Policy: An Outlook
 
  
            Journal
      
      International; OECD
      Bulletin for International Taxation 2015 (Volume 69), No. 10
      In this article, the authors propose the debate of “evolutionary” international tax reform, inter alia, revisiting the current discussion on base erosion and profit shifting (BEPS), and suggesting a renewed emphasis on knowledge-based capital within the framework of the arm’s length principle in respect of transfer pricing and other specific anti-avoidance rules.