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身边的经济学·社会常识英语精读30篇（9）

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How Cross-National Tax Treaty Networks Enable Profit Shifting — Even Without Traditional Havens

How Cross-National Tax Treaty Networks Enable Profit Shifting — Even Without Traditional Havens

跨国税收协定网络如何促成利润转移——即使不依赖传统避税港

  1. Modern profit shifting increasingly exploits mismatches between treaty partners’ domestic definitions of permanent establishment and digital service taxation.
  2. Treaty shopping—routing profits through jurisdictions with favorable bilateral agreements—requires no physical presence, only strategic incorporation.
  3. Developing countries often sign treaties offering extensive relief without negotiating safeguards against base erosion or requiring minimum substance tests.
  4. Multinationals use hybrid mismatch arrangements where payments qualify as deductible expenses in one jurisdiction but escape taxation elsewhere entirely.
  5. OECD’s Pillar Two framework addresses rate gaps but struggles with treaty-based carve-outs that preserve preferential treatment for specific sectors.
  6. Domestic anti-abuse rules remain unenforceable if treaties explicitly override them—a common clause in older agreements.
  7. Revenue authorities lack mutual agreement procedure capacity to resolve disputes involving complex multi-jurisdictional value chains.
  8. Digital services taxes emerged precisely because treaty networks proved inadequate for taxing intangible value creation remotely.
  9. Treaty negotiations now include mandatory arbitration clauses, yet outcomes remain opaque and inaccessible to public scrutiny.
  10. Profit attribution methodologies still rely on outdated arm’s-length principles ill-suited for integrated global platforms.
  11. Systemic reform requires treaty modernization that embeds transparency obligations and dynamic adjustment triggers—not static bilateral concessions.
  12. Tax sovereignty today depends less on unilateral legislation than on coordinated renegotiation of the entire treaty architecture.
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