Base Erosion and Profit Shifting (BEPS)

Análisis

Base Erosion and Profit Shifting (BEPS)

Tax is in the headlines in a manner few could have predicted – even a year or two ago. This has led to a range of issues for businesses to consider, including the OECD's Base Erosion and Profit Shifting project.

About BEPS

The OECD began work on their BEPS project to address concerns that current principles of national and international taxation were failing to keep pace with the global nature of modern trading and business models. In particular, a perception that existing rules give businesses too much opportunity for arbitraging tax rates and regimes.

While views vary, one clear and consistent message is that the matters on the OECD Action Plan agenda are set to significantly shape the means by which governments collect tax and companies align their tax affairs and business models in the decade ahead. Given the OECD’s pace of work, change is inevitable and will be swift.

Endorsed by the G20 Finance Ministers and Central Bank Governors, the Action Plan will likely be delivered in a short 18 to 24 months timeframe.

View the OECD’s site on Base Erosion and Profit Shifting here.

OECD Timetable and actions

OECD Timetable and actions

OECD’s BEPS Action Plan identifies fifteen specific actions that are needed for governments to address the challenges outlined above. The OECD has set the above timeline for itself to address these fifteen actions in three phases.

Click on each of the links below to find a brief description and expected output of each of the 15 BEPS Actions, along with related documents, commentary, and videos.

   
  • Action 1:

Address the tax challenges of the digital economy

  • Action 2:

Neutralize the effects of hybrid mismatch arrangements

  • Action 3:

Strengthen controlled foreign company (CFC) rules

  • Action 4:

Limit base erosive via interest deductions and other financial payments

  • Action 5:        

Counter harmful tax practices more effectively taking into account transparency and substance

  • Action 6:

Prevent treaty abuse

  • Action 7:

Prevent the artificial avoidance of PE status

  • Action 8:

Transfer Pricing: Intangibles

  • Action 9:

Transfer Pricing: Risk and capital

  • Action 10:

Transfer Pricing: Other high-risk transactions

  • Action 11:  

Establish methodologies to collect and analyze data on BEPS and the actions to address it

  • Action 12:

Require taxpayers to disclose their aggressive tax planning arrangements

  • Action 13:

Re-examine transfer pricing documentation

  • Action 14:

Make dispute resolution mechanisms more effective

  • Action 15: 

Develop a multilateral instrument

OECD’s BEPS initiative – global survey

A summary of the results from Deloitte’s “OECD’s BEPS initiative—a global survey,” completed in March 2014. The survey was intended to gauge clients' and contacts’ views regarding the increased media, political, and activist group interest in “responsible tax” and BEPS, and the resulting impact on their organizations

Download the survey results

OECD’s BEPS initiative – global survey

OECD’s BEPS initiative – analysis of global survey results

Analysis of the results from Deloitte’s “OECD’s BEPS initiative—a global survey,” completed in March 2014. The survey was intended to gauge clients' and contacts’ views regarding the increased media, political, and activist group interest in “responsible tax” and BEPS, and the resulting impact on their organizations

Download the survey analysis

OECD’s BEPS Initiative – analysis of global survey results

Major changes: International tax reform and transparency

A briefing paper from Deloitte UK discusses two major tax issues affecting businesses today: international tax reform (OECD’s Base Erosion and Profit Shifting (BEPS) project) and corporate transparency about their tax affairs.

Download the commentary

Major changes: International tax reform and transparency

 

 

Tune into the Topic: Global debates on Responsible Tax, Anti-avoidance, and BEPS

Discussion and perspective on current tax topics and BEPS from Deloitte partners from Belgium, Canada, the United States, the UK, and France.

Download the commentary

Tune into the Topic: Global debates on Responsible Tax, Anti-avoidance, and BEPS

A global tax [r]Evolution – The changing world of tax

Tax continues to emerge as a significant strategic business issue. There is a growing demand for transparency as part of the global political and media agenda. This thought leadership identifies three components to this global tax [r]Evolution: the administration of tax laws and treaties by jurisdictions, unilateral tax law and treaty changes, and the OECD BEPS project.

Download the thought leadership

A global tax [r]Evolution

BEPS alerts and updates

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