Transfer Pricing - BEPS for Beginners

BEPS for Beginners - New!

There is growing recognition that governments lose substantial corporate tax revenue because of planning aimed at shifting profits to locations where they are subject to more favorable tax treatment, in ways that erode the taxable base, the so-called concept of base erosion and profit shifting (BEPS). MNEs are being accused of dodging taxes worldwide and in particular in developing countries, where tax revenue is critical to foster long-term development. The OECD states that globally US$100-240 billion in corporate income tax (CIT) is lost annually as a result of BEPS, which is approximately 4-10% of global CIT revenues.

BEPS Action Plan

The G20asked the OECD to address this growing problem by creating an action plan to address base erosion and profit shifting (BEPS). This plan identifies a series of domestic and international actions to address the problem and sets timelines for their implementation. Therefore, the release of the BEPS project is considered to be a crackdown on tax arbitrage, which marks “the end of the golden era” for multinational enterprises.

The OECD/G20 BEPS Action Plan final version was released on October 5, 2015. The Action Plan identifies 15 actions along three key pillars: (1) introducing coherence in the domestic rules that affect cross-border activities, (2) reinforcing substance requirements in the existing international standards, (3) improving transparency as well as certainty. The allocation of 15 Actions around three pillars is depicted in the following diagram:


Topics covered in the course

So what does BEPS mean for MNEs? The first and foremost impact on MNEs’ performance is the sudden increase in business costs, i.e., land tax compliance. It is anticipated that a radical reform in global taxation will follow. The  action points that are most important to businesses are described in this course. A brief BEPS analysis is given followed by many practical examples. By means of these applied examples you will understand how BEPS will affect your business and what you should do in order to be BEPS proof.


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