Eureka! A mere week shy of a century since Charlie Chaplin first stumbled onto the Silver Screen, the world’s Tax Supremos finally discovered the wonders of Moving Pictures. Watching the OECD Centre for Tax Policy and Administration’s first webcast on Base Erosion and Profit Shifting (BEPS) on January 23rd, there were times when I wished the new media stars had gone through the normal evolutionary process of testing the primordial soup with a Silent Movie.
This was gut-gripping stuff, dealing with progress on the now famous BEPS 15 point Action Plan endorsed last year by the G20 group of nations. It is an attempt to hammer the growing tendency to double non-taxation in international corporate tax planning which,until recently, starred the very silent Google, Amazon, Starbucks and Apple with various other companies in supporting roles. The CTPA was charged with an incredibly ambitious timetable to change whatever is in the hands of the OECD to change (Model Tax Conventions, Guidelines, new Multilateral Instrument) and provide recommendations for whatever is not. If all goes to plan – and the webcast kept its audience glued to their iPads with optimism on this – the operatives of the CTPA will all be home in their beds in time for Christmas 2015. The boys in the trenches have heard that one before.
The broadcast had an international flavour. It was chaired by an American Carl Reiner lookalike with depressive touches of Woody Allen. His performance indicated that he was clearly aiming at an audition as AT&T’s next Speaking Clock. The four person panel sat in a row bolt upright reminiscent of a 1950’s election broadcast where the suspicious politician always looked scared he (it was almost invariably a he in those days) was going to be shot between the eyes by the strange thing pointing at him called the TV camera. The star of the show was the photogenic Director of the CTPA, Pascal Saint-Amans, sporting a Yasser Arafat five-day growth, chic suit and “I am going to seduce you with my French charm” thick-framed glasses. He was joined by the perfectly coiffed Raffaele Russo, head of the BEPS project, who was either talking to the wrong camera or thought he was lecturing to the sound-man standing a few feet to the right of the cameraman. Marlie de Ruiter, Head of Treaties Transfer Prices and Heaven knows what else, added gender diversity to the proceedings and would have made a perfect partner for Saint-Amans in ‘Strictly Come Dancing’. Completing the line-up was Achim Pross, Head of the International Cooperation and Tax Administration Division, a middle-aged natural bald who reminded us all that, at the end of the day, this was boring tax. The speakers had clearly been trained at the Katherine Hepburn school of drama; as Dorothy Parker said of her: “She ran the whole gamut of emotions from A to B”. Before recording ‘BEPS – The Sequel’, they should watch a few Egyptian Soap Operas where nothing moves EXCEPT the faces.
This was, of course, bureaucracy par excellence. We heard about task forces, programmes, global fora (no fauna), public consultations, white papers, questionnaires, discussion drafts and – could international organizations live without them – meetings in exotic places. There were acronyms (not finding HTP in the Action Plan’s glossary, I googled it to discover that the only reference was the document I was trying to decipher – go figure), diagnoses, deadlines, reporting templates and working parties. What there was not, was any talk about anything concrete actually happening (no worries, the first deadline is eons away in September this year). As to bringing on board any countries other than the 34 rich-world members of the OECD and stray members of the G20 – the only mention was of Latvia and Colombia which, I assume I have understood incorrectly, now represent that hard-to-put-your-finger-on-it “Rest of the World”.
A promising star in the firmament could be Australia’s Tony Abbott – this year’s chairman of the G20. Refreshingly the Aussies have no time for European sophistry (they would probably use another word) and Abbott has already said he doesn’t want a talkfest (that was not the word I had in mind and, what is more, it doesn’t actually exist). If he can get Obama on board – and with all the Action Plans and Acronyms it is still the Americans that set rules as has been obvious with FATCA – there could be interesting developments in 2014. Otherwise, that first tax broadcast being almost exactly a hundred years on from Chaplin’s debut may prove more than a coincidence. Chaplin’s film was “Making a Living” in which he played a swindler pursued by the incompetent Keystone Cops.