Overview of action plan on BEPS

Overview of action plan on BEPS

Read the areas of focus from the OECD's action plan on BEPS.

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Action Plan on BEPS – areas of focus Action Plan on BEPS – expected output Timeline
1. Address the tax challenges of the digital economy Report identifying issues raised by the digital economy and possible actions to 
address them
October 2015
2. Neutralise the effects of hybrid mismatch arrangements Recommendations regarding the design of domestic rules and changes to OECD Model
Tax Convention to counteract hybrid mismatch arrangements
October 2015
3. Designing effective controlled foreign company  rules Recommendations regarding the design of domestic CFC rules October 2015
4. Limiting base erosion involving interest deductions and other financial
payments
Recommendations regarding the design of domestic rules to generally limit
deductions on interest and other financial expense
October 2015
5. Countering harmful tax practices more effectively, taking into account
transparency and substance
Report on review of OECD countries’ tax regimes  September 2014
Guidance on substance criteria for acceptable tax regimes. Develop framework for
spontaneous compulsory sharing of tax rulings 
October 2015
Guidance on Modified Nexus Approach for patent box regimes October 2015
6. Prevent the granting of treaty benefits in inappropriate circumstances Recommendations regarding changes to OECD Model Tax Convention and the design of
domestic tax policy rules for tax treaties
October 2015
7. Prevent the artificial avoidance of permanent establishment Status Recommended changes to OECD Model Tax Convention definition of Permanent
Establishment
October 2015
8. Intangibles – transfer pricing rules Update draft OECD transfer pricing guidance on intangibles October 2015 - single report on Actions 8-10
9. Risk and Capital – transfer pricing rules Changes to the OECD transfer pricing guidelines and possible changes to the OECD
Model Tax Convention on risk and capital
October 2015 - further work on this Action is on-going post BEPS
10. Other High-Risk Transactions – transfer pricing rules Changes to the OECD transfer pricing guidelines and possible changes to the OECD Model Tax Convention on high risk transactions including global supply chains October 2015 - further work on this Action is on-going post BEPS
11. Measuring and monitoring BEPS Recommendations regarding data to be collected and methodologies to analyse
evidence of BEPS
October 2015
12. Mandatory disclosure rules Recommendations regarding the design of domestic tax rules for mandatory
disclosure of tax planning arrangements to include those with international tax
benefits
October 2015
13. Guidance on transfer pricing documentation and country-by-country reporting Guidance on revised transfer pricing documentation and design of domestic rules
for Country-by-Country reporting of information 
October 2015
14. Making dispute resolution mechanisms more effective Changes to OECD Model Tax Convention related to dispute resolution procedures October 2015
15. Developing a multilateral instrument to modify bilateral tax treaties Report identifying the technical feasibility of a multilateral instrument to
implement the BEPS treaty-related measures and amend bilateral tax treaties.
October 2015
Develop a multilateral instrument  End of 2016

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