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The good, the bad and the ugly of the global tax reform deal

The agreement reached by 130 countries has left fertile ground for new and clever techniques to circumvent the rules

Let us not be too curmudgeonly: the agreement by 130 countries to reform international corporate taxation is a big moment. It is not often that a global near-consensus is reached on something with such concrete consequences.

Yet while congratulations are in order, the outcome is mixed at best. Here is the good, the bad and the ugly of the reform.

First, the good. The deal addresses the worst problems of international profit taxation. These flow from the principle that taxing rights follow the residence of corporate entities. That may have made sense when value added arose from physical goods production. When value instead resides in intangible services and intellectual property, it is a recipe for abuse. It is estimated, for example, that 40 per cent of global foreign direct “investment” is structured to lower taxes rather than for actual business investment reasons.

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