Professional Competition in Global Tax Reform: The Case of BEPS Action 13

Rasmus Corlin Christensen

Student thesis: Master thesis


International corporate taxation has risen to the top of the global political agenda in the context of the global financial crisis, fiscal pressures and the consequent need for states to raise revenue. The Base Erosion and Profit Shifting (BEPS) project has emerged as the key global tax reform in this regard. In particular, Action 13 on transfer pricing documentation is significant, as it includes a controversial requirement, country-by-country reporting, and will affect the foundations of transfer pricing. In studying how global rules are made, extant perspectives in international political economy set out from a focus on state bargaining, class dominance or organisational culture. This thesis proposes that emphasising actor interests or grand structures misses an important part of policy-making: professional competition. I argue that professional competition for defining policy issues and solutions plays a key role in outcomes from complex, transnational policy processes like BEPS Action 13. Here, influence in highly technical policy discussions is contingent upon expertise (being able to speak authoritatively) and networks (being listened to). Based on extensive quantitative data and qualitative interviews and observation, I examine the professional competition around BEPS Action 13 from a relationalist approach, focused on professional ecologies. I find that tax law and private sector views are central, underpinning key policy claims, but that varied experience is needed for professional influence. I find that a mixed group of business, civil society and IO professionals are influential, with many having gone through ‘revolving doors’ (strategically moving between work roles), enhancing their prestige. I distinguish two types of influential professional: career diverse professionals (“octopuses”) and well-connected specialists (“arrows”). The former are influential because of their varied expertise, the latter because they are respected through key tax/transfer pricing networks. The importance of expertise and networks is also evident in interest group strategies, where actors seek to leverage the influence of other key professionals through what I term “lobby centres”, in order to gain influence themselves.

EducationsMSc in International Business and Politics, (Graduate Programme) Final Thesis
Publication date2015
Number of pages82