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OECD - Base Erosion & Profit Shifting

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Chapter 11

OECD and G20 BEPS Action Plan: Changes to the International Tax System

• 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.

Assure Transfer Pricing Outcomes are in line with Value Creation : Risk & Capital

Develop rules to prevent BEPS by transferring risks among, or allocating excessive capital to, group members.

This will involve adopting transfer pricing rules or special measures to ensure that inappropriate returns will not accrue to an entity solely because it has contractually assumed risks or has provided capital.

The rules to be developed will also require alignment of returns with value creation. This work will be co-ordinated with the work on interest expense deductions and other financial payments..



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