BEPS, Profit Allocation and the Governance of Tax Planning A mixed-method analysis of post-BEPS documentary change and financial-tax indicator evolution

This thesis examines how the OECD/G20 Base Erosion and Profit Shifting (BEPS) project has affected profit allocation, financial and tax indicators, and the governance of tax planning in multinational enterprises. The central problem is not whether tax planning persists, but how BEPS has reshaped the documentary, governance, transparency, substance and legitimacy conditions under which profit-allocation positions are organised, justified and defended. Two sub-questions structure the study. SQ1 asks how selected financial and tax indicators evolved across multinational enterprises between 2014, 2018 and 2023, and how these developments can be interpreted in the context of BEPS. SQ2 asks how corporate and practitioner documents represent the role of tax professionals in managing documentation, governance, substance and legitimacy. A mixed-method design is adopted. The quantitative component is a descriptive, interpretive comparison of consolidated annual-report indicators for AstraZeneca, Shell and Unilever at three benchmark years (2014, 2018 and 2023). The qualitative component is a deductive, interpretive analysis of a purposive documentary corpus comprising OECD and EU regulatory material, corporate tax strategies (AstraZeneca, Shell, Unilever, Vodafone and TotalEnergies) and practitioner sources. The findings indicate heterogeneous and non-linear company trajectories with no uniform post-BEPS effective-tax-rate pattern, alongside documents that consistently represent tax professionals as governance intermediaries rather than technical compliance specialists only. The principal limitations are the small descriptive sample, the absence of a control group or causal identification, the use of consolidated rather than entity-level data, a quantitative–qualitative sample mismatch, and single-researcher coding. The contribution is an integrated finance-governance interpretation of BEPS centred on the concept of risk-adjusted financial defensibility.