Tax Insights: BEPS – Where are we?

Issue 2013-24

Base erosion and profit shifting (BEPS) continues to be on the top of the agenda of the Organisation for Economic Co-operation and Development (OECD) and the European Commission (EC). This Tax Insights:

  • updates you on the status of BEPS and what to expect
  • helps you deal with the changing environment

Since the release of the BEPS Action Plan on July 19, 2013, both the OECD and the EC have undertaken a number of efforts, with particular focus on:

  • transfer pricing
  • tax transparency
  • hybrid instruments
  • inter-group financing arrangements

As noted below, the OECD has recently announced its timetable for stakeholder input on the expected discussion papers.

In addition, some countries already have initiatives to implement domestic BEPS-related measures. For example:

  • new provisions related to intra-group transactions were introduced (or proposed) in Australia, Brazil, France and Mexico
  • rules on tax residency and substance were adopted in Ireland and the Netherlands