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The G20/OECD Base Erosion and Profit Shifting (BEPS) Project aimed at revising existing tax rules to align the taxation of profit with the location of economic activities and value creation (the “value creation principle”). It has received much commentary in literature and general debates and has been regarded as “the most significant re-write of the international tax rules in a century”, an opportunity to “rebuild a healthy scheme for allocating taxation rights”, having the potential to significantly alter the contours of the international tax regime, transforming the international tax regime, signaling a “new struggle over international taxation”, or representing the “emergence of a new international tax regime”. The OECD claimed that the revised rules represent “the first substantial – and overdue - renovation of the international tax standards in almost a century”.


This is a paper presented at Re-Imagining Tax for the 21st Century: Inspired by the Scholarship of Tim Edgar, February 8-9, 2019 Toronto, Canada.

About the symposium:
This symposium is inspired by the scholarship of the late Tim Edgar and the present turbulence of circumstances that affect taxation. Tim was a distinguished member of the Canadian tax academy and taught in Canada and Australia. He passed away in 2016, at the peak of his career. In his tax scholarship, Tim tackled some of the most challenging issues in tax law and policy. This symposium brings together leading tax scholars in multiple disciplines and tax practitioners in Canada and Australia. Participants will explore fundamental questions, such as: Can progressive personal income tax continue in the 21st century? Must tax law be a hostage of private law constructions? What is the evolving connection between technology and taxation? To what end, the BEPS project?

About the authors:
Jinyan Li, Professor of Law, Co-director, LLM Taxation, Osgoode Hall Law School, York University

Jin Bao, Second-year JD student, Osgoode Hall Law School, York University

Huaning (Christina) Li, Ph.D. candidate, Osgoode Hall Law School, York University

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