One of the most significant developments in international taxation over the past century is undoubtedly the Base Erosion and Profit Shifting (BEPS) initiative. In recent years, numerous anti-tax avoidance measures have been introduced across various countries as a result of BEPS, including Economic Substance, Controlled Foreign Corporation (CFC) rules, Thin Capitalization, and Hybrid Mismatch regulations. BEPS represents the largest anti-tax avoidance initiative in modern history and has profoundly shaped the future of international tax rules.
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