Times have changed
I doubt that many readers will have held spontaneous street parties to celebrate the publication of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS). I got bored just typing the title. And I do not recommend you try to read any of the detail – most of it is incredibly tedious.
But although I can make fun of it the publication is hugely important and marks a big change in the approach to international taxation. In common with most practitioners I was trained in an era when exploiting tax treaties by making profits disappear between the cracks or routeing transactions through third counties to avoid withholding was regarded as the norm. Anybody who questioned the ethics or morality of such activity would have been regarded with considerable bemusement. Things have changed...
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