Abstract

Based on Nobel Laureate Paul Romer’s concept of charter cities and following the models of Hong Kong and Singapore, Honduras is the site of an experimental special regime called Zones for Employment and Economic Development (ZEDEs). The ZEDEs are autonomous regions with their own policies, regulations and courts. They are form of private microstate that seeks to create conditions for direct foreign investment and develop rural areas in Honduras. This article seeks to determine if the tax regimes established in the ZEDEs, according to their General Law and examples of specific statutes, are at risk of being categorized as harmful regimes based on Base Erosion and Profit Shifting (BEPS) Action 5 on Harmful Tax Practices. Tax, BEPS Action 5, Honduras, ZEDEs, Harmful Tax Practices, Special Regime

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