International tax and treaty strategy in resource–rich developing countries: experience and approaches

Interest in international tax issues has seldom been greater than in the aftermath of the financial crisis that broke out in 2008. In addition to the highprofile cases of tax loss recorded in a number of countries a flurry of initiatives emerged from inter-governmental summits and international organizations. The phenomenon of base erosion and profit shifting (BEPS) and the possibility of initiatives to mitigate damaging effects were the subjects of a joint OECD and G20 project. The IMF (2014) published a major paper on spillovers in international taxation, showing that macroeconomic spillovers from weaknesses in the international tax architecture were significant – especially for developing countries.