Taxation, International Cooperation and the 2030 Sustainable Development Agenda by Mosquera Valderrama, Irma Johanna

Part I
 Global Tax Governance and Developing
 Countries

Chapter 1
 Getting the Short End of the Stick: Power
 Relations and Their Distributive Outcomes
 for Lower-Income Countries in Transfer
 Pricing Governance
 Cassandra Vet, Danny Cassimon, and Anne Van de Vijver
 1.1 Introduction
 Within the shadow of the G20-OECD Base Erosion and Profit Shifting (BEPS)
 Project, transfer pricing experts pack up their suitcases to go and assist developing
 countries in their efforts to implement a complex regime of transfer pricing auditing
 (Peters 2015; Tax Inspectors Without Borders 2018). At first glance, these efforts
 support the reduction of fiscal losses caused by “aggressive” transfer pricing prac
tices, an important channel of corporate tax avoidance in Sub-Saharan Africa (Fuest
 and Riedel 2012). Yet, while these efforts strengthen the audit capacity of develop
ing countries, the rules that guide these capacity development projects reinforce the
 distributional imbalance of the international tax regime (Magelhaes 2018). This
 chapter sheds light on the power relations at play during the G20-OECD reform of
 transfer pricing guidelines to highlight how these relations shape the distributional
 outcomes of the international tax regime.
 Mosquera Valderrama (2015, 2018) already argued that the reform should not
 only offer a way out of the collective action problem developing countries face in the
 regulation of transfer pricing but also bring about solutions that are efficient and
 implementable within the tax culture and context of these countries. From this view,
 the legitimacy of the BEPS project depends on more than the sole representation of

Taxation, International Cooperation and the 2030 Sustainable Development Agenda by Mosquera Valderrama, Irma Johanna