BEPS – focus shifts toward implementation
The OECD BEPS train continues to roll on, most recently with the meeting of the G20 Finance Ministers and Central Bank Governors held on 9-10 February 2015 in Istanbul.
As the BEPS project progresses into 2015 and beyond, the focus is moving towards identifying practical and efficient implementation strategies.
Several countries have adopted measures consistent with, or as a result of, BEPS recommendations. Some of the more recent examples include France and Japan moving to prevent certain hybrid financing arrangements. Meanwhile in the UK, draft legislation has been introduced to facilitate Country-by-Country reporting.
The Communiqué from the meeting reiterated the G20’s support for the BEPS project and key actions which were released prior to the meeting on 6 February 2015, and relate to:
- Country-by-Country (“CbC”) reporting implementation guidance;
- Master and Local file reporting arrangements;
- Creation of a multilateral instrument; and
- Harmful tax practices and IP regimes.
This increased emphasis on the implementation of BEPS recommendations is particularly evident in the very specific guidance provided on CbC reporting, discussed below.