Developing countries

Secondary BEPS agenda

One of the interesting developments in the area of BEPS is the emergence of what’s been called a “secondary BEPS agenda” in regard to developing countries. This phrase was used by Joel Cooper of the World Bank at a Asia Pacific transfer pricing conference in Singapore.

He is referring to a number of issues which have been identified as of particular interest to developing countries. Some of these issues are covered in the OECD’s report on the impact of BEPS in low income countries.

The issues include the following :

  • The question of tax incentives to encourage foreign investment : good policy or bad?
  • Taxation of indirect transfers
  • Outbound service fee payments
  • In regard to transfer pricing : lack of information on comparables
  • And should developing countries show more reluctance to enter into double tax treaties?
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