Motivated by the 2008-09 financial crisis, the international
public opinion started to vigorously protest against international
tax plannings of large multinationals enterprises. Loopholes and
mismatches in tax legislations of different countries were being
used to achieve significant reduction or deferral of taxes.
Although such tax plannings were in accordance with the
legislation, they were deemed immoral by politicians around the
world, who found it hard to explain to the public the reasons why
domestic legislation permits multinational enterprises to avoid
their fair share of taxes.
In November 2012, in Mexico, leaders from the 19th largest world
economies and from the European Union (the so-called G20) requested
the Organization for Economic Cooperation and Development (OECD) to
prepare a study to tackle tax base erosion and the shifting of
profits to jurisdictions with low or nil taxation, or without
economic substantial activity. The OECD Base Erosion and
