Tax evasion and tax avoidance: the tax payers view • Tax systems are local and not international. Cross border activity runs risk of double tax. No superpower to oversee it all. • MNEs, certainly those quoted on stock exchanges, use codes of conduct. These require compliance with the rules; no exception. • Fair share is not a term we can use; it’s arbitrary and not based on legal rules. • Changing the TP rules to advantage LDCs can be discussed but means less profit to DCs. Will they approve? MNEs have only one profit and can’t inflate it to accommodate all countries. • We favour for all countries an enhanced relationship (ER) between taxpayer and Revenue. This comes with internal control framework and transparency from side of taxpayer and with knowledge and trust from side of Revenue. Hence no need to publish data on per country basis to respond to profit and pricing questions. • We favour capacity building for LDCs. An audit based on an internal control framework based on ER ought to be sufficient to address questions raised about pricing. • The OECD should take into account complexity of its TPG guidelines and related topics; especially the revisions and new issues make compliance for LDCs more difficult to handle. The UN TP Manual will address some of these aspects but does not intend to replace the OECD TPG. • A global consolidated tax system is utopia. No other tax base appears ready to globally take over CIT without problems we currently see. • Dialogue and facts are key to the solution of the issue.
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