Many governments and tax authorities have been looking for new sources of income as a result of the recent economic crisis. Similarly, multinational companies seek to capitalize on the differences between local law and double taxation treaties to transfer profits to countries and regions with low or no taxation through established corporate structures and tax practices around the world. As a result of the reactions, a number of studies were launched under the auspices of the G20 and the European Union Commission in order to prevent multinational corporations from paying lower taxes as a result of profits transferred to other countries and to ensure that these corporations pay fair taxes on their shares. The most well-known of these studies is the new project on “Base Erosion and Profit Shifting (BEPS)” announced in February 2013 by the Organization for Economic Cooperation and Development (OECD), commissioned by the leaders of the G-20 countries.

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