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Base erosion and profit sharing paper


We are living in a post-GFC world where economies, trade, commerce and technology are rapidly changing. In this evolving environment, the question is whether the tax policies and rules should also change, and if so, how?

This paper unpacks this question by drilling into key BEPS issues, outlining the current state of play, examining viable reform options, and speculating how BEPS will affect the tax system in the future. It covers:

  • BEPS - What is it and what does it mean?
  • the international context
  • the Australian context and insights into the forging of the Australian Policy
  • possible BEPS-driven reform and implications for the taxpayers and the ATO.

Author profiles

Dr Niv Tadmore CTA
Photo of author, Niv TADMORE Dr Tadmore is a Band 1 practitioner leading the Australian tax team of international law firm Jones Day. He has vast experience working for more than 20 years with large-market taxpayers from diverse industries, such upstream and downstream energy and resources, infrastructure, digital and tech, and pharmaceutical. The team is known for its hands-on practical approach to the prevention and resolution of tax disputes. Niv has represented the Tax Institute and Law Council on various ATO and Treasury Committees. He is a global Vice-President of the International Fiscal Association and the President of the Australian Branch. Niv is also a member of two tax academic boards: Melbourne University and New York University. - Current at 30 November 2020
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Benjamin Lancaster ATI
Benjamin is an Of Counsel in the Australian tax team of international law firm Jones Day. Benjamin predominately practices in the area of tax dispute resolution, with a particular focus on transfer pricing and other international tax issues. He has extensive experience in responding to audits, managing objection processes, providing strategic advice, and conducting tax litigation. - Current at 22 July 2022
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This was presented at Corporate Tax Retreat .

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Announced unenacted

Author(s):  Trevor PASCALL

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Reinventing the ATO - ready, willing and underway

Author(s):  Neil OLESEN

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