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goveRnMenT ReSPonSIbIlITIeS<br />
Every activity we found in this study took place in<br />
accordance with the way laws and regulations are<br />
routinely interpreted at national level, and frequently<br />
with the explicit agreement of government<br />
agencies. Developed and developing country<br />
governments must therefore work together in a<br />
number of areas:<br />
1. Strengthen tax legislation and revenue<br />
administration capacity in developing countries to<br />
deal with taxing multinational companies.<br />
2. Improve the transparency of corporate reporting,<br />
by making companies’ financial reports and<br />
beneficial ownership information accessible to the<br />
public, and creating a global country-by-country<br />
financial reporting standard. Our research in many<br />
countries was inhibited by the absence of such<br />
transparency, in particular the unavailability of<br />
companies’ accounts.<br />
3. Developing countries must not give away their<br />
right to tax royalties, management fees and other<br />
foreign payments at source, especially when<br />
negotiating double tax agreements. It is striking<br />
that the likely tax loss to Ghana and Zambia’s<br />
governments from the schemes we uncovered has<br />
been increased as a result of their double taxation<br />
treaties with Switzerland and the Netherlands.<br />
4. Developed countries, meanwhile, should<br />
examine and where necessary reform the way they<br />
tax multinationals – such as tax treaty networks,<br />
withholding taxes, and Controlled Foreign<br />
Company rules – to make tax avoidance<br />
in developing countries less worthwhile, not<br />
more lucrative.<br />
5. G20 and EU member states must also work<br />
together to bring a threat of renewed action to bear<br />
against tax havens.<br />
6. Upgrade the United Nations Committee of<br />
Tax Experts to an intergovernmental body, in which<br />
the political issues of international taxation can<br />
be articulated.<br />
The bigger prize must be a system that does not<br />
allow large multinational companies to strip out<br />
taxable profits from their subsidiaries, exploiting<br />
the value of their intangible assets, the ambiguity<br />
of the arm’s length price, and the information<br />
asymmetry between themselves and revenue<br />
authorities. It must be a system under which<br />
developing countries are able to hold on to a<br />
bigger share of taxation from multinationals based<br />
in richer countries.<br />
As countries around the world face gaping fiscal<br />
deficits, tax dodging has become an issue on<br />
which governments, pressure groups and ordinary<br />
people around the world are finally calling time.<br />
“by fAR The<br />
gReATeST<br />
ConTRIbuTIon<br />
buSIneSS<br />
CAn MAke To<br />
DeveloPMenT IS<br />
ThRough The veRy<br />
ACT of RunnIng ITS<br />
buSIneSS – PAyIng<br />
SuPPlIeRS, PAyIng<br />
WAgeS, PAyIng<br />
TAxeS.” GRAHAM<br />
MACkAY, SABMILLER<br />
CHIEF ExECUTIVE<br />
11 <strong>Calling</strong> time