Meaning
Shifting income to low tax jurisdictions through profit strategies reduces the taxable profit base of a multinational entity. Base erosion typically occurs when multinational entities use internal payments for interest or royalties to move value away from high tax territories. It reduces the total tax liability without a corresponding change in the underlying economic activity.
Jurisdictional Arbitrage
Tax authorities monitor the ratio of local expenses to global revenues to identify aggressive planning. The presence of base erosion often leads to investigations into whether intercompany charges reflect fair market value. Regulators use transfer pricing rules to claw back income that has been moved offshore.
Fiscal Impact
National budgets suffer when companies shift profits to tax havens through artificial arrangements. Base erosion creates a gap between where value is created and where it is taxed. Such imbalance forces governments to adjust their corporate tax codes.
Double Taxation
International treaties aim to prevent the same income from being taxed twice while closing gaps that allow for zero taxation. Combating base erosion requires a coordinated effort between nations to ensure that income is recognized in the proper jurisdiction. Mutual agreement procedures help resolve disputes between different tax offices.
These frameworks establish a floor for corporate taxes to prevent a race to the bottom between competing nations.