BEPS Action 12 – Mandatory Disclosure Rules

BEPS Action 12 - Disclosure of Aggressive Tax Planning BEPS Action 12 aims to increase the information flow on tax risks to tax administrations and tax policy makers. Recommendations provide a modular framework that enables countries without mandatory disclosure rules to design a regime that fits their need to obtain early information on potentially aggressive […]

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BEPS Action 11 – Data Analysis

BEPS Action 11 - Measuring and Monitoring BEPS BEPS Action 11 attempts to find a way to track the scale and economic impact of BEPS. This action is different from other actions in that it is of a supportive nature towards the BEPS Project then that it targets BEPS itself. In quantifying BEPS the OECD […]

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BEPS Actions 8-10 – Transfer Pricing

BEPS Actions 8–10 – Aligning Transfer Pricing Outcomes with Value Creation Within the BEPS project three actions have been initiated to target concerns around transfer pricing. Increasing globalization of the economy has led to an increase in intra-group trade. To determine the conditions of intra-group trade, including the price, transfer pricing rules have been set […]

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BEPS Action 7 – Permanent Establishment Status

BEPS Action 7 - Preventing the Artificial Avoidance of Permanent Establishment Status BEPS Action 7 provides a review of the definition of a permanent establishment. This is needed because generally tax treaties provide that profits of a foreign enterprise are taxable in a state only when it has a permanent establishment to which the profits […]

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BEPS Action 6 – Treaty Abuse

BEPS Action 6 – Preventing the Granting of Treaty Benefits in Inappropriate Circumstances BEPS Action 6 identifies treaty shopping as one of the most important sources of BEPS concerns. Countries that do not have anti-abuse provisions in their tax treaties are exposed to lower tax revenues. Therefore it has been agreed between countries to include […]

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BEPS Action 5 – Harmful Tax Practices

BEPS Action 5 In 1998 the report Harmful Tax Competition: An Emerging Global Issue was published by the OECD. BEPS Action 5 has continued the work on harmful tax practices as the underlying policy concerns are as relevant today as they were in 1998. The concern is with the risk that preferential tax regimes and […]

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BEPS Action 4 – Interest Deductions

BEPS Action 4 BEPS Action 4 makes recommendations on best practices in the design of rules to address base erosion and profit shifting (BEPS) using interest and other economically equivalent payments. The recommendation made in 2015 is to align interest deductions with taxable economic activity.  The focus of Action 4 is on the use of […]

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BEPS Action 3 – CFC Rules

BEPS Action 3 BEPS Action 3 sets out recommendations for the design of Controlled Foreign Company (CFC) rules. These rules apply to entities with a controlling interest in a foreign subsidiary. The goal is to prevent the stripping of the taxable base from the country of residence by shifting income to a foreign subsidiary. These […]

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BEPS Action 2 – Hybrids

BEPS Action 2 Hybrid mismatch arrangements is a rather common practice to seek and use differences in the tax treatment of an entity or instrument in two or more tax jurisdictions to achieve double non-taxation, including long-term deferral. A hybrid mismatch arises when the tax treatment of the payments under a hybrid financial instrument or […]

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BEPS Action 1 – Digital Economy

In September 2013 the Task Force on the Digital Economy (TFDE) was established with the goal to develop a report identifying issues raised by the digital economy and detailed options to address them by September 2014. The work that has been done has resulted in BEPS Action 1 - Addressing the Tax Challenges of the […]

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