Organisation for Economic Co-operation and Development (OECD) released final reports on all 15 focus areas in its Action Plan on Base Erosion and Profit Shifting (BEPS).
The OECD also briefly discussed the “post-BEPS environment,” stressing the importance of focusing on implementation of the BEPS recommendations in a consistent and coherent manner, monitoring the impact on both double nontaxation and double taxation. The explanatory statement indicates that OECD and G20 countries have agreed to continue to work together on BEPS until 2020 with an intent to develop “a more inclusive framework to support and monitor the implementation of the BEPS package.”
This Alert provides a high-level overview of the documents released by the OECD on 5 October with respect to the BEPS Action Plan.
The OECD described the final BEPS packages as containing recommendations that fall in several different categories:
- Agreed minimum standards: covering treaty abuse, country-by-country reporting and dispute resolution
- Reinforced international standards: being the revised OECD Transfer Pricing Guidelines and the revised OECD Model Tax Convention
- Common approaches and best practices for domestic law: hybrid mismatch arrangements, controlled foreign company rules and disclosure of aggressive tax planning
- Analytical reports: highlighting the tax challenges of the digital economy, data and analysis with respect to BEPS and the multilateral instrument for implementing treaty based recommendations