Australia: Implications of BEPS deliverables for Australian businesses

Implications of BEPS deliverables

The KPMG member firm in Australia this week provided the following reports concerning the OECD’s base erosion and profit shifting (BEPS) deliverables and implications for Australian businesses:

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Tax treaties - The OECD’s report titled “Preventing the Granting of Treaty Benefits in Inappropriate Circumstances” deals with mechanisms to stop treaty shopping, and notes that treaties are to be aimed at determining there is no double non-taxation. It recommends a cost-benefit analysis before treaties are signed.

 

Read a September 2014 report

 

Two key OECD BEPS recommendations to address tax treaty abuse - The OECD’s launch of their recommendations on base erosion and profit shifting (BEPS) work included as a key deliverable, the OECD’s recommendation to tighten up access to treaty benefits.

 

Read a September 2014 report

 

Transfer pricing documentation, disclosure for country-by-country reporting - The BEPS Action Plan reports provide new guidance on transfer pricing documentation based around a three-tiered structure: 

  • A master file containing standardised information relevant for all members of a multinational enterprise (MNE)
  • A local file referring specifically to material transactions of the local taxpayer
  • A country-by-country report containing certain information relating to the global allocation of the MNE’s income and taxes paid together with certain indicators of the location of economic activity within the MNE group

 

Read a September 2014 report

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