Base Erosion and Profit Sharing

Base Erosion and Profit Shifting

Governments’ Policies Versus Corporate Strategies


Hosted by the Master in Corporate Tax Law, 

Dondena Center for Research on Social Dynamics, and 

Angelo Sraffa Department of Legal Studies


21 May 2014


Room N06

Piazza Sraffa 13


The shifting of profits across borders through purposeful planning shields profits earned in high-tax jurisdictions from their natural tax rates and has become an emerging international policy issue. In 2013 the OECD provided a topical definition of “base erosion and profit shifting” (BEPS) and proposed a policy agenda to address this phenomenon at a global level (OECD, Addressing Base Erosion and Profit Shifting, Paris, 2013) which has also attracted the attention of national governments and the EU. The concern over these issues has recently escalated in major corporate tax cases involving multinationals: in the US, cases have been scrutinized by the Senate and similar issues have been discussed in EU countries, such as Germany, the UK and Italy, while the EU has issued a proposal for a consolidation system based on apportionment (CCCTB) and is currently developing initiatives to counteract aggressive tax strategies. BEPS raises major tax compliance risks, in particular if global multinational firms turn to aggressive cross-border tax planning that erodes corporate national tax bases. This is particularly relevant with reference to the digital economy. The conference will look at the policies that can be adopted by governments to prevent BEPS in their capacity of residence- countries (through worldwide tax consolidation), or in their capacity of source-countries (through so called “destination- based taxes”). It will also address the current corporate strategies that are implemented by multinational firms, with particular emphasis on the techniques, such as transfer price, that are currently used to structure their value chain in light of tax considerations and discuss the interaction of policies by governments with governance standards of multinationals.


9:30am Welcome Addresses

Francesco Saita Dean, Graduate School Università Bocconi

Damiano Canale Head, Angelo Sraffa Department of Legal Studies, Università Bocconi

Ross Macmillan Director, Carlo F. Dondena Center for Research on Social Dynamics, Università Bocconi


10:00am Morning Session

Governments’ Policies: A global scenario

Chair Carlo Garbarino, Università Bocconi


Opening Remarks

Angelo Contrino, Università Bocconi



Daniel Gutmann, Paris Sorbonne University

Ruth Mason, University of Virginia

Donato Raponi, European Commission

Daniel Shaviro, NYU School of Law

Kees Van Raad, Leiden University


2:30pm Afternoon Session

Corporate Strategies, Taxes and Governance

Chair Giorgia Maffini, Oxford University, Centre for Business Taxation


Opening Remarks

Giampaolo Arachi, Carlo F. Dondena Center for Research on Social Dynamics, Università Bocconi



Ian Brimicombe, AstraZeneca

Fabrizia Lapecorella, Director, Finance Department, Italian Ministry for the Economy and Finance

Thornton Matheson, Fiscal Affairs Department, IMF

Roberto Moro, Telecom Italia

Paul Morton, Reed Elsevier Group


Closing Remarks

Andrea Manzitti Director, MDT Master in Corporate Tax Law, Università Bocconi


Official program
















Last updated 02 May 2014 - 07:40:27