In the age of globalization, the global markets have become more coherence and more influence to every economic so that Multi-national enterprises (MNE) also address a great part of global (GDP) (OECD, 2013) Moreover, globalization has arisen from county-specific working model to global model found on the integrated supply chains which included the various worldwide functional. (OECD, 2013)
As a consequence of reason above, the OECD develop and address the model in order to resolve this problem that bought the Base Erosion and Profit Shifting Project and action plan (BEPS) to manage this problem. (OECD, 2013)
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