Date of Award


Document Type


First Advisor

Kim Brooks


The base erosion and profit shifting (BEPS) phenomenon continues to create detrimental consequences in states. BEPS is engendered by two fundamental factors, namely, unhealthy fiscal policies of tax havens and preferential tax regimes, and transfer mispricing by multinational corporations (MNCs). The OECD, through its BEPS Project notes that the lack of transparency in the global activities of MNCs is a major cause of BEPS. To close this gap, the OECD released the CBCR Rules. This thesis discusses the severity of the BEPS phenomenon and assesses the anti-BEPS efforts of the OECD. Upon an assessment of these efforts, this thesis argues for a switch from the application of transfer pricing methods to the formulary apportionment approach. It also argues that this formulary apportionment approach is a better complement to the OECD’s CBCR Rules as a tool by which BEPS can be eliminated globally.