Base Erosion and Profit Shifting (BEPS): Key considerations for real estate funds

BEPS: Key considerations for real estate funds

This report explores the impact on real estate funds of four of the 15 OECD actions: restricting interest deductions, restricting the use of hybrid instruments, limiting treaty benefit and expanding the permanent establishment definition.

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On 5 October 2015 the Organisation for Economic Co-operation and Development (OECD) issued their highly anticipated reports on proposals to tackle what governments perceive as tax-avoidance, using international tax standards (base erosion and profit shifting or BEPS). The development of these proposals was prompted largely by prominent reports in the media of  anumber of well-known multinationals who were paying very little corporate income tax in countries where they were deriving significant sales revenue. As a result of this press coverage, the drive to revise international tax arrangements gained a political impetus that it had previously lacked, and the proposed revisions to the international standards have been turned around according to a remarkably tight timetable.

This report explores the impact on real estate funds of four of the 15 OECD actions:

  • restricting interest deductions
  • restricting the use of hybrid instruments 
  • limiting treaty benefit
  • expanding the permanent establishment definition.

Click below to download the report. 

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