BEPS Action 4 – an update

BEPS Action 4 – an update

An update on the current status of BEPS Action 4 (Limiting Base Erosion Involving Interest Deductions and Other Financial Payments).

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Despite all the uncertainty around Brexit and its impact on tax in recent weeks, the implementation of the OECD’s base erosion and profit shifting (BEPS) Action 4 (Limiting Base Erosion Involving Interest Deductions and Other Financial Payments) is expected to continue along the same timetable as expected before the vote. Action 4 continues to be top of the agenda for lots of businesses, and we have prepared a number of resources to help you keep on top of the recent developments.

We held a webinar on Action 4 on Wednesday 6 July 2016, where we provided a summary of the OECD’s recommendations, detail on the proposed new UK regime and an update on the ongoing UK Government consultation. We also examined the impact for specific sectors and business activities, and provided our insights on the implications for multinational groups operating in the UK. To listen to a recording of the webinar, click here.

As well as the webinar, we have updated our Action 4 tax diary with a new post entitled BEPS Action 4, the EU’s Anti-Tax Avoidance Directive (ATAD) and Brexit. We will soon be posting further updates to the tax diary over the coming fortnight, featuring slides from the webinar and follow ups to some of the many questions which were asked by participants of the webinar.

The OECD and the UK Government are continuing to consult on the implementation of Action 4. The UK Government consultation is already open, and will remain open until 4 August 2016. We would encourage those businesses affected to consider making representations, to ensure that the Government has as full a picture as possible of the impact of Action 4 on UK taxpayers. The promised OECD discussion paper on the group ratio rule, which was expected to be released on 6 July 2016, has now been pushed back to 11 July – we will cover this in a future Tax Matters Digest.


For further information please contact :

John Monds

Sarah Beeraje

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