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The OECD-G20 project on Base Erosion and Profit Shifting (BEPS) is the largest reform of the international tax architecture in decades. The BEPS project aims to ensure that multinationals pay their taxes in the jurisdictions where they create value and where their economic activity takes place. When it is fully implemented, it will substantially alter the global governance architecture for taxation. This is a commendable goal, yet the BEPS project can be criticized for not sufficiently tailoring to the specific needs of developing countries. While it has made a laudable attempt to be more attentive towards developingcountries with the creation of the BEPS inclusive framework, this concerns the implementation phase of BEPS. The agenda-setting and decision-making process only included the G20 and OECD countries. Against this background, it is unclear how and if the BEPS project considered the specific needs of developing countries, especially in light of the Sustainable Development Goals (SDGs). This paper will examine this issue by addressing the following questions: (i) Were the Sustainable Development Goals (SDGs) and the interests of developing countries to attract investment considered throughout the BEPS Process? (ii) What issues of international taxation, beyond BEPS, should be addressed to fulfill developing countries' domestic resource mobilization needs to achieve the 2030 Agenda for Sustainable Development. We conclude with a set of recommendations to the international global tax governance architecture to be more inclusive and responsive to development countries’ needs..
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