The G20/OECD BEPS Project has resulted in many changes to both domestic law and tax treaties,including the adoption of anti-hybrid rules,earningsstripping rules to restrict the deduction of interest expenses,enhanced ...The G20/OECD BEPS Project has resulted in many changes to both domestic law and tax treaties,including the adoption of anti-hybrid rules,earningsstripping rules to restrict the deduction of interest expenses,enhanced transfer pricing rules and a multilateral treaty modifying hundreds of tax treaty changes.These extensive changes led to calls from both taxpayers and governments for enhancements to tax certainty.The BRITACOM has embraced these calls for enhanced tax certainty and made it one of its priority action items.This article puts current discussions about tax certainty into a broader context of the international tax system.It describes the nature and importance of tax certainty as a fundamental tax policy goal as well as the frequent conflicts between certainty and fairness in designing tax legislation and reviews the recent work of the IMF,the OECD and the BRITACOM on tax certainty.The article then explores the major sources of uncertainty,including deficiencies in tax legislation and tax administration,and discusses some methods for improving tax certainty for developing countries,including drafting better tax legislation,streamlining tax administration and adopting more efficient dispute-resolution mechanisms.展开更多
文摘The G20/OECD BEPS Project has resulted in many changes to both domestic law and tax treaties,including the adoption of anti-hybrid rules,earningsstripping rules to restrict the deduction of interest expenses,enhanced transfer pricing rules and a multilateral treaty modifying hundreds of tax treaty changes.These extensive changes led to calls from both taxpayers and governments for enhancements to tax certainty.The BRITACOM has embraced these calls for enhanced tax certainty and made it one of its priority action items.This article puts current discussions about tax certainty into a broader context of the international tax system.It describes the nature and importance of tax certainty as a fundamental tax policy goal as well as the frequent conflicts between certainty and fairness in designing tax legislation and reviews the recent work of the IMF,the OECD and the BRITACOM on tax certainty.The article then explores the major sources of uncertainty,including deficiencies in tax legislation and tax administration,and discusses some methods for improving tax certainty for developing countries,including drafting better tax legislation,streamlining tax administration and adopting more efficient dispute-resolution mechanisms.
