Anti-BEPS measures in forum countries

Resource Information

The work Anti-BEPS measures in forum countries represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Anti-BEPS measures in forum countries

Subject

• BEPS Project (OECD)
• CFC
• CbCR
• MLI
• PE
• digital economy
• dispute resolution
• hybrid transaction
• interest deduction
• transfer pricing
• treaty abuse

Language

eng

Summary

Because of the concerns of a number of countries about deliberate corporate tax base reduction, otherwise known as BEPS, the G-20 requested the OECD to address BEPS. BEPS includes tax planning strategies that exploit various 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. It also includes the use of transfer pricing policies that maximize income in low-tax countries or activities, while minimizing it in higher-tax areas. 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. QUESTIONS: With respect to BEPS Actions VIII, IX, X and XIII, on Transfer Pricing and Documentation, 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 relevant BEPS Actions? Within the professional tax community in HC, what has been the reaction to the measures that have been taken? What practical implications do you see of the measures that have been taken by HC? What should practitioners and business entities be considering to deal with the application of these measures? What concerns do you have, if any, with the measures that have been taken? B. If HC has not yet addressed the Actions listed above, in your view, why not? Is it because it already has adequate provisions on those issues, or has no interest in those BEPS issues, or there has been a recent change in government, or for some other reason? What is your perspective on the possibility for future developments in that area?

Citation source

In: Transfer pricing forum. - Arlington. - Vol. 7 (2016), no. 2 (August) ; 67 p

Geographic coverage

International

Language note

English