handbook-tb

IntroductionWithin the United Nations, the Committee of Experts on InternationalCooperation in Tax Matters (UN Tax Committee) has, over the years,been addressing issues in international tax cooperation, giving specialattention to developing countries. Its deliberations have includedissues relevant to protecting and broadening the tax base of developingcountries, as well as the effective combating of tax evasion and taxavoidance.In recent years, there has been strong political momentum amongdeveloped countries to curtail base erosion and profit shifting (BEPS)by multinational enterprises engaged in a wide range of cross-bordertax planning techniques that allow them to pay little or no tax anywherein the world. At the request of the G20 Finance Ministers, theOrganisation for Economic Co-operation and Development (OECD)released, in February 2013, a report outlining BEPS issues and, in Julyof the same year, followed up with an action plan designed to addressthese issues in a coordinated and comprehensive manner. Specifically,the OECD Action Plan on BEPS was to provide countries with domesticand international instruments that would better align rights to taxwith economic activities. The Action Plan was organized around 15actions, to be implemented by specified deadlines during 2014-2015.The OECD Action Plan recognized that developing countriesalso face issues related to BEPS, although these issues may have a differentimpact on them given the specificities of their legal and administrativesystems. The Action Plan also called for a prominent role for theUnited Nations in providing the perspective of developing countries.In response, the UN Tax Committee, at its ninth session (Geneva, 21-25October 2013), set up the Subcommittee on Base Erosion and ProfitShifting Issues for Developing Countries (Subcommittee on BEPS) andmandated it to draw upon its own experience and engage with otherrelevant entities, particularly the OECD, with a view to monitoringdevelopments on BEPS, communicating on such issues with officials indeveloping countries and facilitating the input of the views and experiencesof these countries into the relevant ongoing work of the UnitedNations and the OECD.vii