4. Conclusion and Recommendations
The taxation of transnational corporations will remain
an important and difficult issue as long as we have a
globalised economy. There will also probably be certain
forms of tax havens or tax haven practices, or at least
tax competition between states. There will be no global
tax policy in the foreseeable future. Thus tax evasion and
aggressive tax avoidance by transnational corporations
will remain on the agenda.
Tax avoidance by corporations involves the use of lowtax
countries and preferential tax regimes. It is often
connected with transfer pricing of intra-firm trade, for
physical goods, but increasingly also for intangibles involving
fees and royalties – which can be heavily abused
in order to lower the tax burden for the corporation as a
whole. Methods that have gained importance in recent
years involve the abuse of qualification mismatches between
different jurisdictions for hybrid entities, financial
instruments, and derivatives.
Despite the difficulties in tackling tax avoidance, governments
must not abandon their national and international
efforts in this direction. However, the current solutions
to tackle aggressive tax avoidance and tax evasion only
mitigate some of the problems. Obviously, they are often
incomplete or insufficient. Consequently, policymakers,
civil society, and the public at large need to rethink
how to ensure a sufficient tax base