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Multinational enterprises have been facing disputes with tax authorities since their very inception and these have only been increasing over the course of time, and with the implementation of the proposals suggested in the Base Erosion and Profit Shifting project a further increase in the number of disputes is predicted. This can also be attributed to the fact that BEPS is primarily aimed at combating tax evasion and not simplifying or clarifying dispute resolution framework. As BEPS will soon
