Speaking at a Global Transfer Pricing Forum in Paris last week, Cym Lowell, Vice-Chairman of the International Chamber of Commerce Commission on Taxation said that business practices were dated and often followed a prescription laid out for the post-World War I world.
“The world has changed dramatically since the 1920s when treaty policy attributed income to creditor countries,” Mr Lowell said. “Today, many of those debtors have become creditors, and prior creditors are now debtors. Unfortunately, the treaty paradigm has not kept pace.”
Mr Lowell told participants that rather than criticising business behaviour, it was time to develop policies consistent with today’s world. This, he said could be one element of facilitating global growth.
Sponsored by International Tax Review and TPWeek, the forum, now in its 12th year, took place on 24-25 September in Paris.
Mr Lowell is an experienced international tax lawyer who has specialized in transfer pricing and related qualified authority matters for a career spanning almost 40 years.
The ICC Commission on Taxation promotes an international tax system that eliminates tax obstacles to cross-border trade and investment.
It examines global or international fiscal problems, as well as issues that arise within national tax administrations. The Commission’s mandate includes both direct taxes (income and corporation tax) and indirect taxes (value added tax and AT and goods and services tax).