The Resource Anti-BEPS measures

Anti-BEPS measures

Anti-BEPS measures
Anti-BEPS measures
  • FACTS: Because of the concerns of a number of countries about designed corporate tax base reduction, otherwise known as "base erosion and profit shifting" (BEPS), the G-20 requested the OECD to address BEPS. BEPS includes tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low- or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid. On 19 July 2013, the OECD issued its Action Plan on Base Erosion and Profit Shifting, which set forth a two-year timeline for developing solutions to BEPS. The final OECD package was issued on 5 October 2015. The BEPS plan comprises Actions in the following areas: I. Digital Economy; II. Hybrids-Structures and Transactions; III. Controlled Foreign Corporations; IV. Interest Deductions; V. Harmful Tax Practices; VI. Treaty Abuse; VII. Permanent Establishments; XI. BEPS Data Analysis; XII. Disclosure of Aggressive Tax Planning; XIII Country-by-Country Reporting; XIV. Dispute Resolution; XV. Multilateral Tax Instrument
  • QUESTIONS: With respect to each of the BEPS Actions listed above (other than Actions VIII, IX, and X on Transfer Pricing, for which see the Transfer Pricing Forum), please respond to the following questions: A. What is the current thinking with respect to Host Country (HC) laws, regulations or other pronouncements that have been issued [or proposed] with respect to the BEPS Actions? For example, from a practical point of view, what should practitioners and/or business entities be considering with respect to application of these measures; within the tax community in HC, what has been the reaction to the measures that have been taken; what concerns do you have, if any, with the measures that have been taken? B. If HC has not yet addressed certain of the Actions listed above, why not? Is it because it already has adequate provisions on those BEPS issues, it has no interest in those BEPS issues, there has been a recent change in government, or for some other reason? What is your perspective on the possibility for future developments in this area?
Citation source
In: Tax management international forum. - London. - Vol. 37 (2016), no. 3 (September) ; 61 p
Language note
  • BEPS
  • BEPS Action Plan
Anti-BEPS measures

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