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Ameliorating the Exacerbation of Economic Inequality Through Tax Havens: A Comprehensive Approach for India

I. INTRODUCTION

Now, it is not uncommon to see the uncommon names of rich celebrities featured in multiple paper leaks. People resort to tax havens for three basic reasons, i.e., firstly, to subvert the rule of law, to serve their elitist interests; secondly, to impede the implementation of the policies carved out by government authorities for the welfare of all people, rather than of few; and thirdly, to ensure the concentration of wealth and resources in the top-notch section of society.2However, it is unfortunate that after thousands of pages of scholarship on the detrimental effects of tax havens, they still continue to exist today in major parts of the world. What is stopping the United States of America from issuing sanctions against the property of Vladimir Putin is one such implication of Tax Havens.3

As has been noted by Richard Murphy, the reasons for the continued existence of tax havens are self-evident.4 To begin with, governments and concerned authorities have been overly focused on the subject of taxation, although the concerns that tax havens pose are considerably larger. Second, political leaders in major countries have been hesitant to shut down the illegally carried out commercial activities in tax havens.5 Such reluctance on their part is quite obvious since many of these activities appear to be encouraged and promoted by their sponsors. Lastly, governments across the world are underestimating the magnitude of the damage that tax havens pose to economic stability, equality and welfare of the people. While cumulative efforts have been made to tackle the tax abuse, the author believes that the same is inadequate. Last year, at the G20 Summit, global leaders endorsed a minimum corporate tax of 15%, toward reducing tax avoidance by multinational corporations that attempt to shift their profits offshore. This paper would deal with such measures in detail in the following sections.

This paper would deal with how tax havens exacerbate income inequality. In the first part of the paper, the author would explain the loss that India incurs due to the shifting of profits to tax havens and evasions. In the second part, the author would embark on discussing the inter- relationship between inequality and tax evasions on account of tax havens. In the third part, the existing measures taken to combat such evasion would be evaluated and further measures and mechanisms would be explored to efficiently deal with the issue.

II. EXTENT OF REVENUE LOSS IN INDIA ON ACCOUNT OF TAX EVASIONS AND SHIFTING OF PROFITS TO TAX HAVENS

While the exact amount of the uncollected tax in India remains unclear, it is the major implication of tax havens that the country suffers from. Tax abuse due to uncollected tax inhibits the growth of the country and puts a limit on the available pool of revenue, restricting them from accessing what is rightfully theirs. The dearth of revenue then forms the pretext for imposing austerity, devastating the lives of millions, by forcing them in poverty, while the elite class becomes more rich, largely unaffected by the stern economic measures because their assets are located offshore in tax havens, free from the taxation by the home government.

According to a report published by the Tax Justice Institute in October 2021, India loses $16,830.3 million annually in tax due to abusive tax evasion practices. 6 The total loss is equivalent to 0.7% of the GDP.7 Total annual tax as a percentage of GDP has increased from 0.41% of the GDP in 2020 to 0.7% in 2021.8Mauritius, Singapore, and the Netherlands are the leading countries where the most tax evasion occurs from the perspective of India.9 These top three tax havens account for 59% of cumulative FDI inflows and 55% of cumulative FDI outflows.10 However, while India continues to incur a tax revenue loss of around $220.5 million (offshore wealth) due to shifting of profits to these tax havens, India itself does not find any place in any worldwide ranking as a corporate tax haven.11 Consequently, no other country suffers a tax loss as a result of India’s actions.

In the past few years, there have been multiple paper leaks, which disclosed the number of individuals involved in tax evasions by routing their assets through these tax havens. Secret records from HSBC’s bank, Switzerland were released in 2015, revealing that the bank assisted roughly 1200 Indians in evading taxes.12 According to the reports, the amount kept in this bank was in the range of $4 billion.13 Thereafter Panama Papers, a largest-ever leak of more than 11.5million financial and legal data from the ‘global’ law firm Mossack Fonseca in Panama City, exposed criminality, corruption, and wrongdoing by the wealthy and powerful who hid their money in covert tax havens.14 The names of 500 Indians who defied the country’s tax norms and regulations were revealed in the incident. The Pandora Papers leaks had the name of more than 380 Indians in 2021. While the matter is being investigated by the Finance Ministry, not much has been done to prevent such subversion of tax revenues.

While the NDA Government must be appreciated for its efforts in tackling the nuisance of tax evasion, a lot more needs to be done. In an investigation conducted by ICIJ in 2015, India was placed at sixteenth rank among the countries with the greatest amount ($) in HSBC, Geneva.15 The total amount of money associated with Indian clients in the Bank amounted to US$876.3 million.16 In an attempt to tackle such abusive diversion of money, in 2015, India enacted the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015. However, despite the efforts, figures released by the Swiss National Bank in 2018 pointed towards a 50% increase in money stored by Indians in 2017 to 1.01 billion Swiss francs (about Rs 7000 crore).17

III. HOW TAX EVASIONS PERPETUATE INEQUALITY 

The above-mentioned leaks demonstrate how the wealthy and powerful are able to simply dodge their social commitments, can avoid paying taxes and hide their money in offshore entities. A major problem in tackling such evasion is that Indian law does not prohibit the acquisition of off- the-shelf companies in tax havens. Not only in India but in all the major jurisdictions, the floating of offshore entities to regulate investments is not considered illegal.18These are the loopholes in the investment regulations, which are exploited by the corporate lawyers, to evade taxes while the lower and middle-class income groups end up bearing the brunt of taxation policies of the country. Consequently, the economic inequality between these two sections of society keeps on widening exponentially.

According to the World Inequality Report, 2022, India stands amongst the most unequal countries in terms of both income inequality and wealth inequality.19 According to estimates, in 2021, the top 10% of Indians held 57% of total national income, while the lowest 50% held only 13%.20. In yet another recent analysis by Oxfam India on inequality, the combined wealth of India’s billionaires increased (almost doubled) in 2021, while 84% of Indian households saw their earnings fall and 4.6 crore people fell into abject poverty due to the pandemic.21 Further, there has been a consistent increase in inequality, which is evident by the fact that within a span of the last five years, the difference between spending and consumption of the rich and poor have almost doubled. The richest 57 billionaires in India own the same amount of money as the poorest 70% of the population.22 An Oxfam report (2017) suggested that it was possible to lift 90 million people out of extreme poverty by 2019, if the rise in inequality could be stopped and maintained at the current levels. It also observed that reduction of inequality by 10 points, which is equivalent to the reduction of inequality by 35%, could help lift another 83 million people.23

The apparent impunity with which India’s wealthy and powerful continue to avoid paying taxes not only increases public outrage over rising income disparity, but also emphasises the importance of comprehensive tax reform. India must pool all of its resources to establish the social and physical infrastructure that will enable the still-poor sectors of its population to escape poverty. On that front, a sustained and considerable loss of tax revenue stymies development. Furthermore, when the wealthy can store their riches overseas with the intention of relocating to another country in the future, they have hardly any motive to invest in safeguarding domestic institutions. That is a perilous route that could result in turmoil and anarchy.

Nicholas Shaxson, in his book, has noted four reasons as to why inequality is perpetuated by tax evasion through taxhavens.24 To begin with, he notes that financial capital isn’t the only type of capital available. Social capital, consisting of an educated and experienced workforce, a reliable business environment, an accommodative judiciary and so on—are more important. Economist Martin Wolf has also observed that , “Access to capital is not, in fact, the decisive constraint on economic growth. It is social and human capital, as well as the overall policy regime that matter.” Maintenance of these social and human capital needs tax revenues as much as possible! Secondly, in common parlance, the term ‘taxation’ is usually associated with revenue. However, revenue represents only one of the four “Rs” of the taxation. The other three “Rs” refer to redistribution, representation and repricing. The goal of ‘redistribution’ is to reduce the levels of inequality. It is the inequality and not the actual rates of poverty and income, which is a determinant factor of how countries perform on nearly every metric of well-being, from “life expectancy to obesity to delinquency to depression to teenage pregnancy.”25 The third element,‘ representation’ stems from the fact that rulers must negotiate with citizens in order to collect taxes, which paves the way for more accountability and representation. 26 ‘Repricing’ is the fourth element, which entails changing prices inorder to discourage certain behaviours. 27 Routing the profits and revenue to the secret jurisdictions, to be kept safely in tax havens, undermine these four elements of taxation.

Simply put, modern democracies are founded on a fundamental social contract, that is, everyone must pay fair and transparent taxes in order to fund access to a variety of public goods and services. While what “fair” and “transparent” taxation entails can be questioned and debated in the country, bypassing the norms and regulations would not be in the best interest of any nation. If some of the wealthiest individuals and corporations exploit tax havens and fiscal dissimulation to avoid paying taxes, this core social contract is jeopardised. The very concept of fiscal consent, which is at the heart of modern democracies, is at risk of collapsing if middle-class taxpayers believe they are paying higher effective tax rates in comparison to their richer counterparts.28

IV. LEGAL AND POLICY REFORMS

This section looks at some of the most common legal and policy remedies to the offshore world’s issues, such as the fact that it increases income and wealth disparity. This section will focus on tax transparency techniques that are used to prevent aggressive tax avoidance.29

A. Initiative to Counter Multinational Tax Avoidance : Base Erosion and Profit Sharing Project

In most cases, there is an information gap between taxpayers and concerned tax authorities. Taxpayers are aware of how the tax authorities should calculate their tax liabilities, however, tax authorities do not have relevant information regarding the corporate or illicit income of the individual taxpayers as well as firms. Consequently, it may be difficult for these tax authorities to uncover illegal financial transactions by taxpayers. As a solution to this problem, it is suggested that the legislature enact the laws or norms requiring taxpayers or third parties to disclose required and complete information to the tax authorities in order to enable them to appropriately estimate a tax liability of the taxpayer.30 To combat tax revenue losses, OECD & G-20 launched the Base Erosion and Profit Sharing (BEPS) reforms in 2013.31 The new Country- by-Country Reporting (CbCR) system is one of the primary developments to come out of the BEPS project, which proposes forcing multinational corporations to declare tax and other payments in every country where they engage in operations.32 While India does not have any such agreement with other countries, because India is not a part of G20. However, the Indian government should take efforts to formulate similar agreements with bilateral groups like ASEAN, BIMSTEC, SAARC, et cetera, wherein the participating governments would be required to enact domestic tax legislation requiring multinational firm taxpayers to report tax payments, which should aid transfer pricing audits.

B. Global Minimum Tax

In October 2021, India with 136 other countries, agreed to a Global Tax Deal, wherein the countries decided to impose a minimum corporate tax rate of 15%.33 The deal envisages an equitable system of taxing big firms’ profits in the markets where they are earned. It is designed to address the shelling out of low effective tax rates by major tech giants such as Google, Facebook, Apple, et cetera. Multinational corporations having global sales of USD 868 million would be subject to the global minimum tax rate. There are two pillars in the deal. As per the Pillar 1, which corresponds to the Minimum Tax aspect, governments could impose whatever local corporation tax rate they wanted, but if it is observed that companies pay lower rates in one nation in comparison to another, their host nation may “top up” their taxes to the 15% minimum, negating the benefit of transferring earnings. As per the Pillar 2, which corresponds to there distribution of additional profits to the market jurisdictions, countries where the revenues are earned have the authority to tax 25% of the excessive profit of the multinational corporations, i.e., the profit above 10% of the revenue.

Companies like Facebook and Google will be required to pay taxes to nations where their customer base is situated under the proposed method. Because traditional regulations highlight the requirement to tax cross-border earnings where value is contributed to a cross-border transaction, that is, typically where the firm’s head office was located, this is an altogether new approach to taxing global income. The above mentioned global minimum tax, would increase the tax revenues of India substantially, because earlier the government was unable to tax considerable gains these corporations made not withstanding the fact that millions of their consumers involved in the profit-making process were the citizens of the host nation.34 If this minimum tax is implemented properly, it will likely limit these companies’ capacity to move cross-border earnings to tax havens. This initiative would prevent the countries from cutting their corporate tax rate unsustainably in order to attract the capital onshore. Such competing tendencies of few nations to lower the taxes, reduces the global tax obligations of the MNCs, which increases the disposable income in the hands of the shareholders and top management of the corporations. However, when minimum tax is applied globally, it would have a redistributive effect by increasing the tax costs on shareholders and management to the extent that they increase the tax liabilities of the corporations. Consequently, there may be less pressure to concentrate taxation on the laborers of the corporations. This would enable the governments to serve more vulnerable residents because the minimum tax initiatives collect more revenue.

C. Withholding tax on investments in Tax Havens

Tax authorities could benefit from a cross-border withholding tax on worldwide investments to help them enforce national tax rules.35 The goal is to construct a revamped version of gross withholding taxes on cross-border payments for global investments made in tax havens. The tax will not apply to investments made in nations with effective tracking mechanisms for taxing overseas investments. The author suggests that information related to bank accounts and transactions should be automatically exchanged with the investor’s home nation by the concerned tax authority. However, if the tax authority fails to automatically exchange the required information, a tax on the transferred assets and/or any subsequent investment income may be imposed by the home country. This mechanism secures tax payment through withholding and gives the government a new source of data to compare to the taxpayer’s tax returns.

D. Global Financial Registry

Major issue faced by the government in collection of taxes is that the governments frequently are unable to trace the beneficial owners of cross-border investments because in certain countries business entities are allowed to set up their investments without disclosing the genuine ownership. While OECD countries have taken the initiative to establish the Common Reporting Standard (CRS), India will not be able to take the benefit of such initiative.36 However, the CRS provides an important lesson for India and other countries to engage in bilateral negotiations on the same lines. In CRS, the participating nations agree to implement the laws requiring the identification of beneficial owners. Governments might pursue offshore tax offenders if they had information regarding who owned what.

V. CONCLUSION

The offshore world was created to serve the interests of society’s wealthiest citizens. Individual taxpayers with a lot of money use offshore havens to hide their assets and to avoid paying taxes. While the middle class taxpayers bear the brunt of heavy taxation by the government to meet the revenue demands of the nation, the rich get richer by escaping their tax liabilities. The offshore world facilitates these consequences, which lead to drained treasuries, throughout the developing nations. Based on the disclosures in numerous paper leaks, there is accumulating evidence that ultra-rich individuals have been unlawfully hiding chunks of their riches offshore for centuries in wealthy democracies. The existence of parallel financial sections—one for the wealthy (haves) and one for the poor (have nots)—endangers the democratic world’s legitimacy, which is based on the ideals of equal opportunity. Thus, it is the need of the hour that governments across the world come together to fight the abusive practices of tax havens in order to bridge the exponentially rising inequality gap.

VI. BIBLIOGRAPHY

Journals and Articles

Arthur J. Cockfield, Cross-border Big Data Flows and Taxpayer Privacy, ETHICS & TAX’N 379 (2020) …………….. 9

Arthur J. Cockfield, International Tax Transparency, 1 PERSP. TAX L. & POL’Y 1 (2020) ………… 7

Gil S. Epstein & Ira N. Gang, Why pay taxes when no one else does?, SSRN ELECTRONIC JOURNAL (2009) …………….. 5

Leandra Lederman & Joseph Dugan, Information Matters in Tax Enforcement, BYU L. REV. 145 (2020) …………….. 8

Margot Salomon, Why Should it Matter that Others Have More? – Poverty, Inequality and the Potential ofInternational Human Rights Law LSE LEGAL STUDIES(2010) ………………………………………………………………………………………….. 7

Michael G. Allingham & Agnar Sandmo, Income tax evasion: A theoretical analysis, 1 JOURNAL OF PUBLIC ECONOMICS 330 (1972)   2

Books

MARTIN WOLF, WHY GLOBALIZATION WORKS 283 (2005)……………………………………………………. 7

NICHOLAS SHAXSON, TREASURE ISLANDS: UNCOVERING THE DAMAGE OF OFFSHORE BANKING AND TAX HAVENS 179(2011) …………… 6

RICHARD MURPHY, DIRTY SECRETS: HOW TAX HAVENS DESTROY THE ECONOMY, Chapter 1 (2018) ………… 2

RITU SARIN, JAY MAZOOMDAAR & VAIDYANATHAN P. IYER, THE PANAMA PAPERS: THE UNTOLD INDIA STORY OF THE TRAILBLAZING GLOBAL OFFSHORE INVESTIGATION 37(2019)………………………………………………………………………………. 4

Reports and Regulations

Department for Promotion of Industry and Internal Trade, Quaterly Fact Sheet Fact Sheet On Foreign DirectInvestment (Fdi) From April, 2000 To March, 2019 (2019), available athttps://dpiit.gov.in/sites/default/files/FDI_Factsheet_27May2019.pdf (last visited Mar 27, 2022). …………. 3

ICIJ, Swiss Leaks (2021), available at https://projects.icij.org/swiss-leaks/countries/ind (last visited Mar 27, 2022). …………….. 4

OECD, Addressing Base Erosion And Profit Shifting 38 (2013)……………………………………………. 8

OECD, Addressing Base Erosion And Profit Shifting 38 (2013)……………………………………………. 8

OECD, Addressing The Tax Challenges Of The Digital Economy, Action 1: Final Report 3 (2015) …………….. 9

Oxfam, Inequality Kills: India Supplement 2022 7 (2022)……………………………………………………. 5

Tax Justice Network, The State of Tax Justice 2021 (2021), available at https://taxjustice.net/wp-content/uploads/2021/11/State_of_Tax_Justice_Report_2021_ENGLISH.pdf (last visited Mar 27, 2022). ………………. 3

Will Fitzgibbon, The panama papers: Exposing the Rogue Offshore Finance Industry ICIJ (2022),https://www.icij.org/investigations/panama-papers/ (last visited Mar 27, 2022). …………… 4

World Inequality Lab, World Inequality Report 3 (2022)……………………………………………………… 5

Online Sources

Barun Jha, 57 Indian billionaires own wealth equal to bottom 70% of country’s population, THE WIRE,https://thewire.in/economy/57-indian-billionaires-own-wealth-equal-to-bottom-70-of- countrys-population (lastvisited Mar 27, 2022).         6

David Leigh et al., HSBC files show how Swiss Bank helped clients Dodge Taxes and hide millions,        THE     GUARDIAN          (2015), available athttps://www.theguardian.com/business/2015/feb/08/hsbc-files-expose-swiss-bank-clients- dodge-taxes-hide-millions(last visited Mar 27, 2022)………………………………………………………………… 4

José Antonio Ocampo, A global financial registry to fight tax evasion, THE HINDU BUSINESS LINE (2018),            https://www.thehindubusinessline.com/opinion/a-global-financial-registry-to-fight-tax-evasion/article62294537.ece (last visited Mar 27, 2022)……………………………………. 10

Lubna Kably, 136 countries reach historic deal on Global Minimum Corporate Tax, THE TIMES OF INDIA (2021) https://timesofindia.indiatimes.com/business/international-business/136- countries-reach-an-agreement-to-distribute-mnes-profits-among-customer-centric-countries- and-introduce-a-minimum-global-tax-rate-of-15/articleshow/86877954.cms (last visited Mar 27, 2022). ……………….. 8

Nisha Agrawal & Namit, Agarwal, Inequality and the Indian Private Sector, IIC QUARTERLY, 43(2) (2016). 6

Patrick Wintour, UK minister in BVI for urgent talks on sanctioning Russian oligarchs, THE GUARDIAN   (2022),https://www.theguardian.com/world/2022/mar/23/uk-minister-in-bvi-for-urgent-talks-on-sanctioning-russian-oligarchs (last visited Mar 27, 2022)…………………………… 2

Sugata Ghosh, Swiss bank: Why Swiss banks are still popular among Indians despite being under GovernmentScanner, THE ECONOMIC TIMES, available athttps://economictimes.indiatimes.com/industry/banking/finance/banking/why-swiss-banks-are-still-popular-among-indians-despite-being-under-government- scanner/articleshow/64834365.cms (last visitedMar 27, 2022). ………5

2 Michael G. Allingham & Agnar Sandmo, Income tax evasion: A theoretical analysis, 1 JOURNAL OF PUBLIC ECONOMICS 330 (1972).

3 Patrick Wintour, UK minister in BVI for urgent talks on sanctioning Russian oligarchs, THE GUARDIAN (2022),https://www.theguardian.com/world/2022/mar/23/uk-minister-in-bvi-for-urgent-talks-on-sanctioning-russian- oligarchs (last visited Mar 27, 2022).

4 RICHARD MURPHY, DIRTY SECRETS: HOW TAX HAVENS DESTROY THE ECONOMY, Chapter 1 (2018).

5 Ibid.

6 Tax Justice Network, The State of Tax Justice 2021 (2021), available at https://taxjustice.net/wp-content/uploads/2021/11/State_of_Tax_Justice_Report_2021_ENGLISH.pdf (last visited Mar 27, 2022).

7 Ibid, at 23.

8 Ibid, at 23.

9 Ibid, at 59.

10 Department for Promotion of Industry and Internal Trade, Quaterly Fact Sheet Fact Sheet On Foreign Direct Investment (Fdi) From April, 2000To March, 2019 (2019), available at https://dpiit.gov.in/sites/default/files/FDI_Factsheet_27May2019.pdf (last visited Mar 27, 2022).

11 Ibid, at 23, 37.

12 David Leigh et al., HSBC files show how Swiss Bank helped clients Dodge Taxes and hide millions, THE GUARDIAN (2015), available athttps://www.theguardian.com/business/2015/feb/08/hsbc-files-expose-swiss-bank- clients-dodge-taxes-hide-millions (last visited Mar 27, 2022).

13 Ibid.

14 Will Fitzgibbon, The panama papers: Exposing the Rogue Offshore Finance Industry ICIJ (2022), https://www.icij.org/investigations/panama-papers/ (last visited Mar 27, 2022).

15 RITU SARIN, JAY MAZOOMDAAR & VAIDYANATHAN P. IYER, THE PANAMA PAPERS: THE UNTOLD INDIA STORY OF THE TRAILBLAZING GLOBAL OFFSHORE INVESTIGATION 37 (2019).

16 ICIJ, Swiss Leaks (2021), available at https://projects.icij.org/swiss-leaks/countries/ind (last visited Mar 27, 2022). 17 Sugata Ghosh, Swissbank: Why Swiss banks are still popular among Indians despite being under Government Scanner, THE ECONOMIC TIMES,   available at https://economictimes.indiatimes.com/industry/banking/finance/banking/why-swiss-banks-are-still-popular-among- indians-despite-being-under-government-scanner/articleshow/64834365.cms (last visited Mar 27, 2022).

18 Gil S. Epstein & Ira N. Gang, Why pay taxes when no one else does?, SSRN ELECTRONIC JOURNAL (2009).

19 World Inequality Lab, World Inequality Report 3 (2022).

20 Ibid, at 197, 198.

21 Oxfam, Inequality Kills: India Supplement 2022 7 (2022)

22 Barun Jha, 57 Indian billionaires own wealth equal to bottom 70% of country’s population, THE WIRE, https://thewire.in/economy/57-indian-billionaires-own-wealth-equal-to-bottom-70-of-countrys-population (last visited Mar27, 2022).

23 Nisha Agrawal & Namit, Agarwal, Inequality and the Indian Private Sector, IIC QUARTERLY, 43(2) (2016).

24 NICHOLAS SHAXSON, TREASURE ISLANDS: UNCOVERING THE DAMAGE OF OFFSHORE BANKING AND TAX HAVENS 179 (2011).

25 MARTIN WOLF, WHY GLOBALIZATION WORKS 283 (2005).

26 Ibid at 284.

27 Nicholas Shaxson, Treasure Islands: Uncovering the Damage of Offshore Banking and Tax Havens 179 (2011)

28 Margot Salomon, Why Should it Matter that Others Have More? – Poverty, Inequality and the Potential of International Human RightsLaw LSE LEGAL STUDIES (2010).

29 Arthur J. Cockfield, International Tax Transparency, 1 PERSP. TAX L. & POL’Y 1 (2020).

30 Leandra Lederman & Joseph Dugan, Information Matters in Tax Enforcement, BYU L. REV. 145 (2020).

31 OECD, Addressing Base Erosion And Profit Shifting 38 (2013).

32 Ibid.

33 Lubna Kably, 136 countries reach historic deal on Global Minimum Corporate Tax, THE TIMES OF INDIA (2021)https://timesofindia.indiatimes.com/business/international-business/136-countries-reach-an-agreement-to-distribute- mnes-profits-among-customer-centric-countries-and-introduce-a-minimum-global-tax-rate-of- 15/articleshow/86877954.cms (last visited Mar 27, 2022).

34 OECD, Addressing The Tax Challenges Of The Digital Economy, Action 1: Final Report 3 (2015).

35 Arthur J. Cockfield, Cross-border Big Data Flows and Taxpayer Privacy, ETHICS & TAX’N 379 (2020).

36 José Antonio Ocampo, A global financial registry to fight tax evasion, THE HINDU BUSINESS LINE (2018),https://www.thehindubusinessline.com/opinion/a-global-financial-registry-to-fight-tax-evasion/article62294537.ece (last visited Mar 27, 2022).

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