Contributions of the Base Erosion and Profit Shifting BEPS Project on Transfer Pricing and Tax Avoidance

Globalization and digitalization lead to flaws and asymmetries in tax rules which were used by multinational companies in their own benefit. Then, to face tax avoidance and tax losses which represents 100 to 240 billion dollars per year, Organization for Economic Co-operation and Development and G-20 implement, since 2012, the Base Erosion and Profit Shifting project, base erosion and profit shifting, which is the most important international reform that tax system has known. This paper aims to understand whether the Base Erosion and Profit Shifting project’s transfer pricing actions mitigate tax avoidance by multinationals through a literature review and a qualitative approach. We interview 05 international tax specialists working in Multinational Companies and Tax Administration. We found that the project’s transfer pricing reforms mitigate tax avoidance in short term. We confirm the first hypothesis, that the Base Erosion and Profit Shifting project’s transfer pricing inputs mitigate tax avoidance in the short term, and following the results obtained, we refute the second hypothesis that Base Erosion and Profit Shifting actions dealing with transfer pricing do not mitigate tax avoidance.