Document Type
Article
Publication Date
1-2016
Abstract
This paper will argue that while there is some innovation in BEPS, it is in fact more of a continuation that a sharp break with the past. Like Alexis de Tocqueville’s French Revolution, BEPS represents both continuity and change. In particular, the single tax principle has formed the theoretical basis of much of the international tax regime from the beginning. And it is in fact this continuity rather than any sharp change that gives the final BEPS package its promise to, as Secretary General Gurria also promised, “put an end to double non-taxation.”
Recommended Citation
Avi-Yonah, Reuven S. "Full Circle? The Single Tax Principle, BEPS." Global Tax'n 1, pt. 1 (2016): 12-22.
Included in
Business Organizations Law Commons, Taxation-Federal Commons, Taxation-Transnational Commons, Tax Law Commons