Full Taxation : The Single Tax Emperor's New Clothes

It has recently been argued in the international tax literature that the OECD Base Erosion and Profit Shifting project (BEPS) reflects and effectuates full taxation, namely an international norm that would suggest that all of a company's income should be taxed in places where it has real business activities, ultimately representing a modern approach to single taxation. This article builds upon this concept and argues that although rhetorically attractive, full taxation is still conceptually inconsistent, particularly because it is incapable of providing any hints as regards where and who should finally be taxed. Most notably, the concept also adopts an overinclusive and instrumental approach, the purpose of which appears to be no other than the legitimatisation of provisions under which if one country does not impose taxation, another country automatically pulls the trigger and does it, ultimately resulting in the unpalatable approach of taxing just for the sake of taxing