According to the OECD, “base erosion constitutes a serious risk to tax revenues, tax sovereignty and tax fairness for OECD members countries and non-members alike a significant cause of base erosion is profit shifting”. Although there has been discontent with the existing framework for many years, considerable impetus has been given to the OECD BEPS project by the G8 and the G20. OECD rhetoric includes statements such as “BEPS offers a global roadmap that will allow governments to collect the tax revenue they need to serve their citizens. It also gives businesses the certainty they need to invest and grow”, and that this is a “once in a century” opportunity to reform the international tax system.

It is clear that the OECD intends to propose evolutionary, rather than revolutionary, reforms. But it is not at all clear that such an approach will generate an international tax system fit for the 21st century. It is not only the practical working of the system that is in doubt, but its conceptual basis. A lack of a good conceptual basis means that reforms may be piecemeal and arbitrary.

This talk will address fundamental issues of principle and practice in the allocation of profits for taxation. It will question the conceptual basis of the existing OECD framework, discuss the BEPS action plan, and consider other potential methods of allocating taxing rights between countries, including methods based on residence, destination and formula apportionment.

This lecture has been organised by the ESRC Centre for the Microeconomic Analysis of Public Policy at IFS and the Chartered Institute of Taxation (CIOT) and is designed to promote serious debate among policy-makers, opinion-formers and the wider tax and economics communities.

Stephen Coleclough, CIOT will open this event and following the lecture we will have a panel debate with Paul Johnson, IFS (chair), Bill Dodwell, Deloitte and Nicholas MacPherson, Permanent Secretary, HM Treasury.

Registration will take place between 18:00 and 18:30 and the event is expected to conclude by 20:00 and will be followed by a drinks reception.

This event is invite only. Please email @email with your affiliation and contact details if you wish to attend.