ABSTRACT
It is difficult to know when significant history is being made. Our professional experience accumulates in layers, some of which do not make much sense without an appreciation of the context, some of which assume greater significance because of what immediately precedes or follows, and some that may not seem important at all until viewed with the benefit of hindsight. The international tax system comes under stress when there is a perception that it no longer delivers a fair result for developed and less developed countries alike, taking into account the evolution of business practices. At such times we may be at the cusp of a fundamental once-in-a-lifetime change, or we may be dealing with a natural yet transient response to a weak global economy in the aftermath of the global financial crisis of 2008 onward.
