Action Plan on BEPS

Action Plan on BEPS

On 19 July 2013, the OECD released its Action Plan on Base Erosion and Profit Shifting (BEPS) identifying 15 specific actions.

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In October 2015, OECD released final reports concentrating on the following matters:

  1. Address tax challenges of the digital economy 
  2. Neutralize effects of hybrid mismatch arrangements 
  3. Strengthen controlled foreign company (CFC) rules 
  4. Limit base erosion via interest deductions and other financial payments
  5. Counter harmful tax practices more effectively, taking into account transparency and substance 
  6. Prevent treaty abuse 
  7. Prevent the artificial avoidance of permanent establishment status 
  8. Assure that transfer pricing outcomes are in line with value creation – Intangibles
  9. Assure that transfer pricing outcomes are in line with value creation – Risks and capital 
  10. Assure that transfer pricing outcomes are in line with value creation – Other high-risk transactions 
  11. Establish methodologies to collect and analyze data on BEPS and the actions to address it 
  12. Require taxpayers to disclose their aggressive tax planning strategies arrangements 
  13. Re-examine transfer pricing documentation 
  14. Make international dispute resolution mechanisms more effective 
  15. Develop a multilateral instrument for implementation of the Action Plan on BEPS and modification of the existing double taxation treaties
     

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