The Legal Regulation On The Base Erosion And Profit Shifting(BEPS)

With the development of Global Economic Integration and Digital Economy,Multi-National Corporations'tax avoidance behavior gradually increased.Especially the Case of Apple Corporation's tax avoidance has triggered an international attention to the Base Erosion and Profit Shifting(BEPS).In July 2013,OECD issued the Action Plan on BEPS to improvetax cooperation between different countries by amending Tax Agreements.In addition,in the case of BEPS problems intensified,many countries have begun to reform the domestic tax laws and amended the bilateral Tax Agreement to deal with the BEPS problem.In our country,with the advancing of "One Belt,One Road",more and more enterprises go abroad at the same time,and it may also bring BEPS risk.So the research on BEPS will help us to improve the legal system of anti-tax avoidance and strengthen foreign tax cooperation.This paper is divided into four parts.The first part is an overview of the Case of Apple Corporation's tax avoidance,to analyse the concrete means to shift profit of this corporation,and discussing the BEPS thinking triggered by this case.The second part mainly introduce the cause of BEPS and the main means of Multi-National Corporation to cause the BEPS,to analyse the main problem which international community should pay attention.The third part analyses the main measures of the international community to deal with the BEPS problem.Mainly analyzing the BEPS action plan report released by OECD,and new measures to deal with this problem of different countries.The fourth part mainly discusses the current situation of legislation of anti-tax avoidance of China and the specific means to deal with BEPS.Then,this paper put forward the opinion according to the problem.