The Reflection on the Magnitude and Disasters of BEPS Schemes

To promote the maximum consensus of the global community on the implementation of the OECD/G20 Final BEPS Package, this paper investigated the magnitude and disasters of BEPS schemes by comparative research and empirical data. This paper analyzed the relevance of ETRs to the magnitude of BEPS, the ratio of corporate tax revenue in GDP in the process of globalization, the relevance of the FDI flows to BEPS, the relevance of the widespread conduit or SPE structures to BEPS schemes and the magnitude of BEPS schemes of U.S.-based MNEs. As the research findings, this paper highlighted the complicated disasters of over speculative BEPS schemes. The BEPS schemes have eroded the integrity of tax bases in both source and residence jurisdictions, deteriorated the quality of the public goods in all relevant jurisdictions, fundamentally undermined the tax justice, imposed unfair burden on domestic taxpayers especially the individuals and small businesses, distorted the free and fair mechanism of market competition, undermined the efficiency of rational market in optimal allocation of the resources and created a booming intermediary industry assisting BEPS, undermined the reasonable trust of global taxpayers in the fairness and integrity of the tax law, hindered the voluntary compliance by the public taxpayers, and injured the reputation of the community of MNEs and worsened off the global business ecology.