Multinational enterprises are changing. This concerns especially their improved ability to fragment their value chains and disperse them geographically. Such global value chains have stimulated economic growth in many parts of the world over the past three decades. However, they also make it increasingly important to rethink current tax policies. On the one hand, governments seek to encourage trade and investment by multinational enterprises by removing tax and regulatory barriers they face. Some governments go even further by resorting to harmful tax competition that drives corporate income taxes to the bottom. At the same time, many multinational enterprises continue to employ enhanced tax arbitrage to minimise their tax obligations across jurisdictions; furthermore, business models are increasingly becoming borderless and highly mobile, and therefore difficult to tax.
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