2017 BEPS Global Survey

Tax Alert - September 2017

Deloitte has recently completed its fourth OECD BEPS Survey (full results available here and more information available here). The annual survey is conducted to gauge the views of multinational companies regarding the Global Tax Reset and the OECD’s BEPS initiative, and the expected resulting impact on their organisations.

The 2017 survey focused on understanding how multinationals’ perspectives on BEPS have changed since the BEPS recommendations went into effect. The survey notes that it will be important that companies take a strategic and multi-disciplinary approach when it comes to addressing the Global Tax Reset. Some of the key findings include:

  • Substantial change is fully expected and being prepared for: 86% of organisations have assessed the potential impact of the BEPS changes to their organisation and 54% have developed additional corporate policies and procedures in relation to this. Further, 50% have changed the way they conduct tax planning for cross-border transactions to address proposed BEPS changes and expected increased scrutiny related to corporate taxation.
  • Major impact on compliance burden: As a result of the OECD BEPS recommendations, 94% of respondents believe that the additional transfer pricing reporting requirements will substantially increase their compliance burden and 66% believe that the increase in the number of foreign permanent establishments will substantially increase their compliance burden.
  • Double tax: 80% believe that double tax will occur as a result of unilateral tax law changes and 75% believe that double tax will arise from some of the BEPS changes even without unilateral legislative changes.
  • Consistency: Only 19% agree that tax administrations will interpret the proposed changes to the transfer pricing guidelines in a consistent manner.
  • Greater scrutiny being placed on companies: 91% of respondents agree that tax structures are under greater scrutiny by tax administrations than a year ago (and 93% believe there will be more tax audit assessments). 53% agree that tax authorities are becoming increasingly aggressive in tax examinations.
  • Foreign permanent establishments: 66% of respondents expect the tax compliance burden to substantially increase as a result of an increase in the number of foreign PEs resulting from BEPS recommendations.
  • Concern over reputational risk and increasing interest in tax: 76% of respondents are concerned about the increase in media, political and activist group interest in corporate taxation. 61% agree that tax planning in their organisation has become a corporate responsibility issue, not just a legal issue.
  •  Additional resources due to BEPS: 29% of respondents indicated they were planning on securing additional resources / headcount wholly or partly as a result of the anticipated changes arising from BEPS initiatives. 
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