With development of technology and globalization of businesses, Multinational enterprises (MNEs) have started designing their business operations in a way to minimize their global tax cost through making effective use of tax rules and applicable exemptions available under tax treaties. However, on the other hand, International Tax Rules have not been able to keep pace with the developments in the world economy, resulting into double non- taxation and stateless income. As a result, Organization for Economic Co-operation and Development (OECD) started to shape out a plan to mitigate harmful tax practices to ward off negative effects of MNEs tax avoidance strategies on national tax base.
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