Assisting Developing Countries in Taxation after the OECD’s BEPS Reports: A Suggested Approach for the Donor Community

This paper explores how the international donor community might most productively offer technical assistance to developing countries in the area of taxation, in light of the OECD’s recently completed study of ‘base erosion and profit shifting’ (BEPS). The paper addresses both the political and the technical constraints facing developing country tax administrations. It recommends that donor agencies seek to build their technical assistance efforts through long-term collaborations with developing country governments, and observes that the most productive technical assistance efforts might extend beyond the boundaries of the particular international tax issues that the BEPS studies address. The paper also explores two particular BEPS-related measures on which productive technical assistance may be especially feasible, namely the implementation of limitations on corporate interest deductions, and the construction of ‘transfer pricing safe harbours’.