OECD - Base Erosion & Profit Shifting

• The (BEPS) Project, an ambitious plan undertaken jointly by the OECD and G20 to overhaul the global international tax system, culminated with a huge report of recommendations that, if adopted, could have a significant impact on cross-border trade.

• On 5 October 2015, the OECD published 13 final reports and an explanatory statement outlining consensus actions under the base erosion and profit shifting (BEPS) project.

Action 1

Address the tax challenges of the digital economy

Action 2

Neutralize the effects of hybrid mismatch arrangements

Action 3

Strengthen Controlled Foreign Company CFC rules

Action 4

Limit base erosion via interest deductions and other financial payments

Action 5

Counter harmful tax practices more effectively, taking into account transparency and substance

Action 6

Prevent treaty abuse

Action 7

Prevent the artificial avoidance of Permanent Establishment (PE) status

Action 8

Aligning transfer pricing outcomes with value creation: intangibles

Action 9

Aligning transfer pricing outcomes with value creation: risks and capital

Action 10

Aligning transfer pricing outcomes with value creation: other high-risk transactions

Action 11

Measuring and monitoring BEPS

Action 12

Require taxpayers to disclose their aggressive tax planning arrangements

Action 13

Re-examine transfer pricing documentation and CbCR

Action 14

Make dispute resolution mechanisms more effective

Action 15

Develop a multilateral instrument