n Improve the existing transfer pricing system with the Arm’s Length Principle as much as possible – e.g., by applying profit split and similar methods;
n Strengthen anti-avoidance rules;
n Set up public centralised registers of companies, trusts, foundations, and similar legal entities, which display the economic beneficiary of the entity;
n Restrict the deductibility of certain capital gains such
as interest, particularly in the case of effective nontaxation
(subject-to-tax clause);
n Apply withholding taxes, particularly for income on intellectual property rights, but not with the result of
lowering taxes;
n Improve the rules on the economic activity of companies in order to prevent letterbox companies;
n Include the above recommendations in double taxation agreements, and use the crediting principle instead of the exemption principle as a general rule;
n Introduce comprehensive country-by-country reporting for all types of corporations;
n Investigate and apply a compulsory and comprehensive unitary taxation, either at regional or even at
global level.
The G20, at their heads of state summit in 5–6 September 2013, as well as countries around the world need to act in order to prevent TNCs from avoiding and evading their taxes. While some of the problems discussed here
can be solved unilaterally, there are others that could be dealt with more effectively through intergovernmental cooperation at the regional or global level.