(A) In cross-border transactions, the exploitation of the differences between domestic tax systems to achieve double non-taxation...
Question:
(A) In cross-border transactions, the exploitation of the differences between domestic tax systems to achieve double non-taxation can result in base erosion and, consequently, a loss of revenue for the two States. In addition to its impact on tax revenues, it also has an overall negative impact on competition, efficiency, transparency, and fairness.Please analyse the above contentions, examining (i) the role of domestic laws in cross-border transactions in international tax law and practice; (ii) the operations of MNEs across borders in the context of their tax obligations; and (iii) the nature and effect of competition referred to above. Please also express your opinion as to the correctness or otherwise of the above contention. Please support your response by reference to appropriate published legal and other sources.