DECLARATION · 2018. 4. 10. · 1. Tax abuse by multinational corporations increases the tax burden...

DECLARATIONof the Independent Commissionfor the Reform of InternationalCorporate Taxation

ABOUT ICRICT

The Independent Commission for the Reform of International CorporateTaxation aims to promote the international corporate tax reform debate througha wider and more inclusive discussion of international tax rules than is possiblethrough any other existing forum; to consider reforms from a perspective ofpublic interest rather than national advantage; and to seek fair, effective andsustainable tax solutions for development.

ICRICT has been established by a broad coalition of civil society and labororganizations including ActionAid, Alliance Sud, CCFD-Terre Solidaire, ChristianAid, the Council of Global Unions, the Global Alliance for Tax Justice, Oxfam,Public Services International, Tax Justice Network and the World Council ofChurches. ICRICT is supported by Friedrich-Ebert-Stiftung.

The views and opinions expressed in this document are those of theCommissioners and do not necessarily reflect the official policy or position ofany of the institutions they represent or the institutions of the establishingcoalition of organizations.

For more information, visit the ICRICT website at www.icrict.org.

© ICRICT June 2015

1. Tax abuse by multinational corporations increases the tax burden on other taxpayers, violates thecorporations’ civic obligations, robs developedand developing countries of critical resources tofight poverty and fund public services,exacerbates income inequality, and increasesdeveloping country reliance on foreign assistance.

2. Abusive multinational corporate tax practices area form of corruption that weakens society anddemands urgent action. This is even true whenthe practices of corporations are within the law,and especially so when corporations have usedtheir political influence to get tax laws thatprovide them scope for such abuses.

3. Multinational corporations act – and thereforeshould likewise be taxed – as single firms doingbusiness across international borders. This isessential because multinational corporationsoften structure transfer pricing and otherfinancial arrangements to allocate profits to shelloperations in low tax jurisdictions.

4. Tax havens facilitate abusive tax practices withenormous negative effects on the globalcommunity.

5. Greater transparency and access to informationare critical first steps to stop tax abuses.

6. Every individual and country is affected bycorporate tax abuse, and therefore the debate overmultinational corporate tax avoidance should bewidened and made more accessible to the public.

7. Inclusive international tax cooperation isessential to combat the challenges posed bymultinational corporate tax abuse.

PREAMBLE

» THE INDEPENDENT COMMISSION FOR THE REFORM OF INTERNATIONAL CORPORATE TAXATION

We are a group of leaders from government,academia, and civil society, including the faithcommunity. Our backgrounds, experience, andexpertise span the globe. With the convictionthat our system of taxing the global profits ofmultinational corporations is broken and that therules and institutions governing the internationalcorporate tax system must change, we haveformed an Independent Commission for theReform of International Corporate Taxation. As a Commission, we have concluded that proposals to reform the current system areclearly insufficient, and the institutionspromoting international tax cooperation are notinclusive enough. We hope that the followingprinciples and recommendations for reform willpromote a wider public debate, which we believeis essential to ensure the creation of aninternational tax system that works for all people.

STATEMENT OF PRINCIPLES

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1. States must reject the artifice that acorporation’s subsidiaries and branches areseparate entities entitled to separatetreatment under tax law, and insteadrecognize that multinational corporations actas single firms conducting business activitiesacross international borders.

2. States should develop model bilateral andmultilateral agreements to enableparticipating jurisdictions to apportionrevenues and costs attributable to amultinational corporation operating in thosejurisdictions.

3. Instead of attributing income from the controlor ownership of intellectual property to a lowtax jurisdiction, the income should beapportioned to the jurisdictions where theintellectual property was developed or, if sold,apportioned according to objective economicfactors such as sales and employment.

4. States should treat a company affiliate of aresident multinational corporation that carriesout business activity in a jurisdiction as apresumptive permanent establishment withtax nexus in that jurisdiction.

5. States should revise the permanentestablishment rules to provide that when acorporation sells or provides downloads ofproducts from the internet to customers in ajurisdiction, exceeding a specified threshold,that business activity creates a permanentestablishment.

6. In the long term, the system for taxing amultinational corporation’s subsidiaries asseparate entities should be replaced by asystem of taxing multinational corporations assingle and unified firms, using formularyapportionment based upon objective factors,such as sales and employment, and withadequate consideration of the source principle.

7. International cooperation for reform must gobeyond the current OECD’s BEPS initiativeand begin to research and negotiate thespecific elements of an internationalconsolidation and apportionment system,including what rules would apply to determinethe tax base and apportion profits amongcountries where multinational firms operate,and how to avoid the vertical disintegration towhich it may give rise.

“States must reject the artifice that a corporation’s

subsidiaries and branches are separate entities entitled toseparate treatment under tax law...

”


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RECOMMENDATIONS FOR REFORM

I. TAX MULTINATIONALS AS SINGLE FIRMS

8. Developed nations, possibly through theOECD, should take the first step to stop thecurrent race to the bottom in corporatetaxation, by agreeing on a minimum corporatetax rate.

9. States should also examine spillover effects oftheir tax preferences for multinationalcorporations and eliminate those thatfacilitate tax avoidance in another country.

10. All states should proactively disclose to thepublic tax incentives, tax preferences, andincome exclusions provided to multinationalcorporations.

11. States should refrain from advocacy, throughdiplomatic or other means, for theirmultinational corporations involved in a taxdispute with other countries.

12. European states should bring additional legalactions before the European Commission toclarify the factors that qualify certaincorporate tax preferences as illegal state aidand to stop the use of those tax preferences.

13. States should promote cooperation to curb taxcompetition, along the lines of such efforts inthe East African Community, through itsefforts to harmonize tax incentives, and in theEuropean Union, through the development ofthe Common Consolidated Corporate Tax Base.

ICRICT

Commission

Meeting

March 18,

2015

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>

II. CURB TAX COMPETITION

© Joel Sheakoski

14. States should impose criminal penalties onabusive tax practices.

15. Multilateral organizations should develop amodel tax withholding system that requiresthe withholding of taxes from interest,dividend, royalty, and other payments madebetween affiliate companies of multinationalcorporate groups before those outboundpayments cross international borders.

16. Multilateral organizations should develop modelprovisions to protect whistleblowers whodisclose abusive corporate tax practices.

17. States should ensure that their taxadministrators have adequate resources,independent authority, and legal protection tocollect taxes owed from multinationalcorporations.

18. Multinational corporations should publish andadhere to a set of ethical principles related topaying taxes, and enunciate an explicitacknowledgement of their civic obligation topay taxes to support the countries in whichthey operate.

19. States must require multinationalcorporations, both public and private, to filecountry-by-country reports and, upon filing,make those reports freely available to all taxadministrators, without requiring separatetreaty or other agreements, so as not todisadvantage developing countries comparedto developed countries and to facilitateefficient and cost-effective tax administration.

20. States should make country-by-countryreports available to the public within 30 daysof filing.

21. States should obtain the names of naturalpersons who are the ultimate beneficialowners of the shares in corporations andupdate those names in public corporateregistries.

22. Multinational corporations in the extractiveindustries should also publicly disclose, on acountry-by-country and project-by-projectbasis, the payments they make togovernments, based on their reports underSection 1504 of the Dodd-Frank Act in theUnited States and the Accounting and Transparency Directives in the EuropeanUnion.

23. Multinational corporations should identify intheir annual, publicly available corporatereports all of their subsidiaries, and not justthe subset of “significant” subsidiaries.

24. States should publicly disclose advancepricing agreements and the outcomes ofmutual agreement procedures and develop amodel form to make key elements publiclyavailable.


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III. STRENGTHEN ENFORCEMENT

IV. INCREASE TRANSPARENCY

25. States should avoid restrictions on taxwithholding in tax treaties.

26. Multilateral organizations should expand theobjectives of model tax treaties to includepreventing double non-taxation, curbingabusive tax practices, and enablinginformation exchange to facilitate effectivetax administration.

27. Multilateral organizations should amend themodel tax treaties to include a general anti-avoidance rule.

28. States should avoid the inclusion of provisionsin investor protection treaties, resourceextraction agreements, or other agreementsthat weaken or circumvent tax law.

“Tax policies of one country can have dire effects on other countries’

ability to mobilize tax revenues to educate their children, provideadequate healthcare, and build safe roads and bridges.

”

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V. REFORM TAX TREATIES

29. Member States should upgrade the UNCommittee of Experts on InternationalCooperation in Tax Matters to anintergovernmental Commission and provide itwith adequate resources.

30. The G20/OECD BEPS project is a step in theright direction, but should be made moreinclusive to reflect the priorities of developingcountries, including through equal voting rightsand equal rights to amend the action plan.

31. Multilateral and other governmentalorganizations should provide increasedresources for capacity building in developingcountries for tax administration, includingthrough South-South cooperation.

32. The UN Global Compact and the OECDGuidelines for Multinational Enterprisesshould be strengthened by explicitlyrecognizing the obligation to pay tax as apreeminent corporate social responsibility.

33. Member States should initiate negotiations todraft a UN convention to combat abusive taxpractices, which should evolve into aconvention that would adopt a consolidationand apportionment system for taxing globalcorporate profits.

34. The international community should continueto search for the most effective and inclusivemechanisms to regulate corporate taxation atthe global level.

VI. BUILD INCLUSIVITY INTO INTERNATIONAL TAX COOPERATION


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RATIONALE

» THE WORLD HAS CHANGED AND SOSHOULD ITS TAX SYSTEM. Globalization haschanged the world economy and rendered thecurrent international corporate tax systemobsolete. Developed countries established thatsystem in the early twentieth century, at a timewhen single firms traded mostly agricultural andmanufactured goods with other corporationslocated in other countries and colonies. Today,however, almost half of global trade occurs withinrelated corporate structures, the services sectorcomprises 63% of global gross domestic product,and developing countries produce nearly one-halfof the global gross domestic product. Moreover,the world is now greatly interconnected. Taxpolicies of one country can have dire effects onother countries’ ability to mobilize tax revenuesnecessary to confront socio-economic deprivationsand rampant inequality as well as to provide basicsocial services such as education for children,adequate healthcare, and safe roads and bridges.

Recently, the abusive tax practices of manymultinational corporations have drawn greatpublic attention. Tax abuse can occur when

multinational corporations relocate businessactivities to avoid taxation and do not pay theirfair share of tax where they do business. Whilethere may be some disagreement about which taxsystem can be said to be ‘fair’, there is virtuallyuniversal consensus that what has occurred isunfair. This tax abuse has incited widespreadpublic anger and triggered governmentinvestigations into the tax practices of many of thebest-known corporations in the world. Theinvestigations have shed light on aggressive taxmaneuvers through the gaping legal loopholes ofthe international corporate tax system. Theseabusive practices are enabled by tax advisors,global banks, tax havens, and governments’acquiescence to the race to the bottom. In manycases, the ‘loopholes’ that multinationals aretaking advantage of are not just accidents; rather,they are the result of concerted lobbying, often bythe very firms that pretend that they are simplyobeying the law. Given the current need for greaterdevelopment financing along with dramaticausterity measures by many governments,exposure of tax abuse has prompted demandsfrom the public to both change the rules and beincluded in the debate.

© middle: European Commission DG ECHO

» HOW THE CURRENT SYSTEM WORKS.The international corporate tax system is based onthe separate entity approach. Under this taxframework, each firm, including the parent orsubsidiary companies in a multinational corporategroup, is treated as a legally separate entity andtaxed accordingly. Within the multinationalcorporate group, subsidiary companies may engagein transactions with other related companies insidethe corporate group or with unrelated companiesoutside of the corporate group. Usually, when twounrelated companies trade with each other, theyhave opposing interests. The paying party is notwilling to pay more than the market price, and theselling party is not willing to sell at less than themarket price. The result is that the negotiations willgenerally result in a true market price for thetransaction, often referred to as an ‘arm’s lengthprice.’ Subsidiary companies may also engage intransactions with related parties. In thesetransactions, however, the related companiesgenerally have common interests. They also may becontrolled by persons who look after the interests ofthe multinational corporate group as a whole aswell as the interests of the parent company.

Related party transactions represent a significantand growing share of global trade. In thesetransactions, the price assigned to value theexchange in a transaction is often referred to as a‘transfer price.’ In order to ensure accuracy, the‘arm’s length principle’ prescribes that transferprices should be the same as the prices that thecompanies would have used if they had beenunrelated parties negotiating under marketconditions, and not part of the same corporategroup. The OECD and the United Nations haveendorsed the arm’s length principle in their ModelTax Conventions, which are widely used as thebasis for bilateral treaties between governments.

» HOW THE CURRENT SYSTEM HASBECOME OBSOLETE. Ensuring that transferprices follow the arm’s length principle is difficulteven when transactions involve goods, due toquality differences between similar products. Butregulating transfer prices has been made evenmore difficult over the past three decades as thedominance of intangible over tangible assets as ashare of company value has been firmlyestablished. Intangible assets include trade names,goodwill, and brand recognition as well asintellectual property, such as patents, copyrights,brands and trademarks, business methodologies,and control of commercial networks. Because thisknowledge-based capital is highly mobile anddifficult to value, the arm’s length principle hasbeen found both practically and theoreticallyflawed in valuing transfers of these assets betweenrelated parties. The fundamental problem is thatmany of these related party transactions, especiallythose involving intangible assets, do not havecommercial counterparts with comparable prices.Moreover, the company and industry data anddocumentation compiled by the corporation often

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ICRICT Commission Meeting March 18, 2015 >© Joel Sheakoski

produce analyses that are difficult to challenge dueto the paucity of readily available and relevantinformation. As a result, transfer pricing audits canbe very expensive and time consuming for taxadministrations in both developed and developingcountries. This dysfunctional system creates vastopportunities for tax abuse.

Tax abuse through transfer pricing occurs whenmultinational companies manipulate the prices ofrelated party transactions to increase profits in lowtax countries and decrease profits in higher taxcountries. This type of manipulation can occurwhen multinational companies charge each otherroyalties and other fees for the use of patents,brands, or trademarks; act as intermediaries forproduct sales and distribution; or make loans andinterest payments to one another. Other economicfunctions, such as management services,corporate treasury, and investment services canalso be delegated among companies within themultinational corporate group to increase taxadvantages. The more complex the web of relatedcompanies within the multinational corporategroup, the easier it is to avoid taxation byinitiating transfers and fact patterns that cannotbe deciphered or disputed. Thus, it has becomepainfully clear that the current separate entityapproach and its transfer pricing system cannotwork in a globally integrated and knowledge-basedeconomy.

» WHAT REALLY MATTERS IN THISDEBATE. As a Commission, we lament thehuman and societal toll of corporate tax abuse.Such abuse is a major obstacle to fighting poverty,ensuring sustainable development, and protectinghuman rights. While the wealthy few havetremendous vested interest in the currentdysfunctional system, boys and girls, women andmen, those living in poverty, the vulnerable andthe marginalized have lost the most. Whencorporations do not pay their fair share of tax inthese countries, essential public services andinfrastructure spending are cut, and the tax burdenis shifted onto ordinary citizens, usually in theform of regressive consumption taxes such asvalue-added taxes (VAT). A recent report by the UNConference on Trade and Development estimatesthe corporate income tax losses for developingcountries due to profit-shifting by multinationalcorporations at one-third of total corporate incometaxes due—an astounding $100 billion per year.The loss of these revenues may be a matter of lifeor death for many people across the globe.

Depriving countries of resources needed to build astate apparatus also negatively affects thecapacity to fund the physical, social, and legalinfrastructure required to enable the flow ofcommerce and protect private rights to tangibleand intangible property. Although some argue that


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© le

ft: SEIU

the corporate and individual tax systems shouldbe integrated, and there should not be any specialtax on corporations, this view ignores the benefitsprovided to corporations by the State.Incorporation is a privilege granted by the state—not a right—and the legal protections it provides,such as limited liability and private propertyrights, facilitate greater investment in researchand development and enable business to beconducted on a large scale, and hence, generatehigher levels of profit.

International corporate tax abuse also createsunfair competitive advantages for multinationalfirms as against domestic enterprises, many ofwhich are small and medium in size; and theeffects of this imbalance have been exacerbatedby unfair trade agreements over the past quartercentury. Moreover, the extraordinary complexity ofthe current system disadvantages honestbusinesses. It creates an environment where theworld’s largest corporations have incentives tocreate complex tax avoidance structures that eventhe largest developed countries’ tax authoritiesstruggle to keep up with. As a result, small anddeveloping countries are hit thrice—higher costsfor administering the tax system, declining taxrevenues, and an artificially decreasedcompetitiveness of their domestic companies.

The current system wastes resources whencountries pay enormous sums of money to enforcetax laws and companies pay inordinate sums ofmoney to tax advisers and make business

decisions to avoid tax rather than create economicvalue. But this debate is not just about theefficient allocation of resources. Rather, it centerson equity: equity between good taxpayers and badtaxpayers, equity between capital and labor, equitybetween the rich and those living in poverty, aswell as equity between countries, includingbetween developed and developing countries.

Today around the world there is increasingconcern about growing inequality and diminishingopportunity. It is simply unconscionable that thetop 1% of the world’s population will own half itswealth by 2016. This inequality is underminingdemocracies, dividing societies, and weakeningeconomic performance throughout the world. Ourbroken system of taxing global corporate profits isan important contributor to growing inequality.

» EFFORTS TO FIX THE BROKEN SYSTEM.Until recently, the debate on internationalcorporate tax has been largely dominated bytechnical discussions monopolized by theinterests of multinational corporations and theirtax advisors. However, recent investigationsconducted by the United States, United Kingdom,and European Union have uncovered multipleexamples of transfer pricing abuses. As a result ofthe political and media focus on this evidence andthe ensuing public outcry, in 2012, the G20called on the OECD to reform the internationalcorporate tax system through the Base Erosionand Profit Shifting (BEPS) initiative. In

“While the wealthy few have

tremendous vested interest in thecurrent dysfunctional system,boys and girls, women and men,those living in poverty, thevulnerable, and the marginalizedhave lost the most.

”

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September 2013, the BEPS Action Plan wasapproved as a G20 project and organized throughthe OECD for delivery by December 2015.

The BEPS initiative will formulaterecommendations to reform the system foradoption through a multilateral treaty (Action 15)to curb profit-shifting (Actions 3, 4, 7); limittransfer pricing abuse (Actions 8-10,13); closetax loopholes created by mismatches in countries’laws (Action 2); and clamp down on tax treatyabuse (Action 6). Other recommendations willfocus on the digital economy, harmful taxpractices, data sources in monitoring baseerosion, disclosure rules, and dispute resolution(Actions 1, 5, 11, 12, 14). Unfortunately, thetargeted reforms of the BEPS project will only

work within the current separate entity system toreduce corporate income tax base erosion.However, we believe that the current separateentity principle is the fundamental problem, andthis core deficiency has not been addressed bythe BEPS project.

For example, the BEPS work on transfer pricinghas produced additional methods to determine anappropriate arm’s length price, in addition to thecurrent five methods. If adopted, they would addeven more variation to the OECD’s Transfer PricingGuidelines for any given ‘facts and circumstances’analysis of the ‘functions performed, assetsemployed and risks assumed’ by each relatedcompany. These patches would make transferpricing regulation an even greater drain ofresources for tax authorities, create more

uncertainty for taxpayers, generate conflict asdifferent tax authorities opt for different methods,and open up new opportunities for tax arbitrage.Thus, by avoiding any rethinking of the separateentity system and creating even more complexitywithin the current faulty framework, the BEPSinitiative has amounted to pouring new wine intoold wineskins.

While some (but not all) countries have a seat atthe table in the G20/OECD BEPS process, theirpositions are largely dictated by parochial nationaleconomic concerns, or even worse, by specialinterests within their countries. Unfortunately, thediscussions in BEPS public consultation meetingshave been dominated by multinationalcorporations, who consistently outnumber civil

society, academic, labor, and countryrepresentatives combined, and are often doublyrepresented by their tax advisers and specialindustry groups in addition to corporateexecutives. These corporations are predominantlyheadquartered in the United States and Europeancountries, who act as staunch allies to protect the‘competitiveness’ of their own multinationals. Forexample, in the BEPS consultation on the taxationof the digital economy, the leading technologycompanies, who commonly stake their claims atthe forefront of technological innovation, stoodunited against any discussion of tax rules thatwould consider the concept of digital presence inthe tax nexus rules, while their home countriesextolled the need for ‘traditionally accepted’ and‘durable’ principles such as physical presence. Inthis context, fundamental principles of the


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“by avoiding any rethinking of the separate entity system and

creating even more complexity within the current faulty framework, theBEPS initiative has amounted to pouring new wine into old wineskins.

”

international corporate tax system have not beenexamined, nor have more practical approaches totaxation been given serious attention.

Moreover, despite the fact that numerousdeveloping countries have attended two rounds ofregional consultation meetings and a group oftwelve developing countries has been invited bythe OECD to participate, they do not have theright to vote. This kind of participation is not theglobal representation required to create rules thatimpact everyone. We believe it is now time toconsider international corporate tax reforms froma global perspective rather than the nationaladvantage of a select number of countries.

» REFORMING THE DEEPERDYSFUNCTION OF OUR GLOBAL TAXSYSTEM. The primary enabler of internationalcorporate tax abuse is the separate entityprinciple—a legal fiction that enables the flow ofvast amounts of taxable income away from theunderlying business operations. We believe theonly effective way to stop this abuse is to treatmultinational corporations as single and unifiedfirms and divide the taxable profits between thecountries where the income generating activitiesare located. If multinational corporations weretaxed as single and unified firms, there would beno transfer pricing because global corporateprofits would be consolidated, and thus no profits

would be gained or lost through intra-companytransactions. Each country would get tax revenuesfrom the multinational group profits in proportionto the business activities conducted there.

This system would require an agreement as to howglobal profits would be divided among the taxingcountries. For example, sales and employmentfactors would reflect the central role of people asconsumers in market countries as well as peopleas producers of both tangible and intangiblegoods and services in source countries. However,division of profits based on the location ofemployees could lead to movement of someemployment functions to low tax countries as wellas vertical disintegration. Therefore, rules such astaxation on the transfer of intangibles as well as‘economic substance’ provisions would benecessary to counteract artificial instances ofvertical disintegration. Additionally, some sectors,such as the extractives industry, would require aspecialized ‘production volume’ factor in additionto sales and employment to more accuratelymeasure business activity.

Systems of ‘formulary apportionment,’ have beenused to divide corporate profits at the subnationallevel in the United States, Canada andSwitzerland for almost a century. In recent years,the European Union has developed a similarsystem that consolidates corporate profits from

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the EU corporate group and apportions themamong EU member states. This proposal, calledthe ‘Common Consolidated Corporate Tax Base,’has been approved by the European Parliament,but has not yet reached the unanimous consensusrequired for full implementation.

Indeed, at the global level, such a unifiedapproach to taxing corporate profits would requiremore inclusive and stronger internationalcooperation as well as focused research to make itwork as efficiently and fairly as possible. However,it is now time to shift away from the separateentity principle and move toward taxation ofmultinational corporations as single and unifiedfirms. During this transition, leading developednations should impose a global minimumcorporate tax rate to stop the race to the bottom.

In addition to reforming the foundational principleof the international tax system, we call on theinternational community to prioritize other areasfor reform:

» TAX INCENTIVES. We believe the globalrace to the bottom on corporate tax incentivesshould be reined in by increased international taxcooperation and commitment to stop theunnecessary loss of resources. While each countryis responsible for its own tax system, no country isunaffected by the tax system of others. In additionto evaluation of the effectiveness of taxpreferences, countries should also examinespillovers caused by their tax preferences formultinational corporations. Such work could alsobe undertaken through a globally representativebody, which could monitor the effects of unfair taxcompetition. Current efforts to further cooperationamong partner states in the East AfricanCommunity, including the development of a Codeof Conduct to prevent harmful taxation and theharmonization of tax incentives are laudable andexemplify the commitment required to worktogether and not compete, because everyone losesin the race to the bottom.

» TRANSPARENCY. We believe that there is aneed for greater transparency of profits and taxespaid in each country by multinationalcorporations, public and private. In light of thestring of recent corporate tax scandals, the publicno longer accepts that corporations, able to hidetheir affairs, will always do the right thing. Greatertransparency, for example, on revenues fromnatural resources, could unleash the potential ofcompanies to make a significant contribution tosustainable development and human rights. Andalthough the issues of taxation of the extractivessector and taxation of High Net Worth Individualsare not primarily a corporate tax issue, weacknowledge and encourage compulsory andvoluntary measures for transparency asexemplified in the Extractives IndustryTransparency Initiative and the creation ofregistries of ultimate beneficial ownership.

» ILLICIT FINANCIAL FLOWS. We alsosupport important efforts to curb illicit financialflows, which result primarily from commercialactivities, including transfer pricing abuse, asrevealed in the recent report of the High-levelPanel on Illicit Financial Flows from Africa,commissioned by the African Ministers ofFinance, Planning and Economic Developmentunder the auspices of the African Union, and theUnited Nations Economic Commission for Africa.

» CAPACITY BUILDING. We recognize thedire need for capacity building in developingcountry tax administrations, but we know thatwithin a faulty system, which imposes undueburdens on developing countries, greater capacityalone is inadequate. We acknowledge the effortsfrom the international community, including theIMF, OECD, UN, and others, who are taking actionto combat corporate tax abuse through capacitybuilding. These efforts should be fully supportedand increased through international taxcooperation.


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ICRICT COMMISSIONERS

Ms. Eva Joly was born in Norwayand is a Member of the EuropeanParliament where she serves asVice-Chair of the SpecialCommittee on Tax rulings.

Rev. Suzanne Matale is the Head of the Zambian Council ofChurches.

Mr. Manuel Montes, born in the Philippines, serves as SeniorAdviser for Financing andDevelopment at The South Centre.

Mr. José Antonio Ocampo(Chairperson) is Colombian andformer United Nations Under-Secretary General and formerMinister of Finance of Colombia.He is currently a Professor atColumbia University.

Mr. Léonce Ndikumana wasborn in Burundi and is aProfessor of Economics at theUniversity of Massachusetts.

Mr. M. Govinda Rao is the formerMember of the FinanceCommission, Member of theEconomic Advisory Council to thePrime Minister of India, andDirector of the National Institute ofPublic Finance and Policy in India.

Ms. Magdalena SepúlvedaCarmona from Chile, is a HumanRights Lawyer and recentlyserved as the United NationsSpecial Rapporteur on ExtremePoverty and Human Rights.

Mr. Joseph Stiglitz is from theUnited States and UniversityProfessor at ColumbiaUniversity. In 2001, he wasawarded the Nobel MemorialPrize in Economics.

Ms. Ifueko Omoigui Okauru served asCommissioner General of Nigeria’sFederal Inland Revenue Service andwas a Member of the Committee ofExperts on International Cooperationin Tax Matters. She is currentlyManaging Partner of ComplianceProfessionals Plc.

The Independent Commission for the Reformof International Corporate Taxation

Contact: [email protected]

DECLARATION · 2018. 4. 10. · 1. Tax abuse by multinational corporations increases the tax burden...

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