AS WE WITNESS CHANGE IN ALL SPHERES OF THE ECONOMY, the world of taxes is not far behind. The changes particularly impacting multinational companies began when Lehman Brothers happened and countries started staring at falling tax revenues.
Two facts stood out. One, MNCs were able to park their profits in tax havens or low-tax jurisdictions; this was nothing new but started pinching in light of declining revenues. Second, with the dominance of the digital economy, old concepts of taxation like the existence of a permanent establishment (PE) to establish a taxable presence were no longer relevant. Also, unless global solutions were found to these issues, each country would evolve unilateral measures, which would result in chaos. The final thing was that some of the largest MNCs likely to be impacted by any change in the status quo were based in the US, and getting the authorities there on board was critical.
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