Base Erosion and Profit Shifting (BEPS): A Collection of Coverage and Analysis - March 2017

This special report reflects the current international tax landscape 18 months after the OECD’s final recommendations on most of the items in its Action Plan on Base Erosion and Profit Shifting. With the bulk of the OECD BEPS work completed, individual countries have rushed to adopt the guidance on transfer pricing, country-by-country reporting and other action items—in some cases, going beyond the OECD’s mandate. At the same time, work on several of the BEPS items—such as profit split, permanent establishment and digital transactions—continues, as does the OECD’s push to have countries sign on to the “multilateral instrument,” a super-treaty that allows countries to adopt the treaty-related recommendations from the BEPS project in one fell swoop.

This special report includes updated news and analysis from Transfer Pricing Report™. 

Full Contents: 

  • Former Treasury Official Addresses U.S. Role in BEPS, Changing Tax Policy, EU Tax Probes of U.S. Companies
  • 60 Countries Expected to Sign Tax Agreement: OECD Official
  • No New U.S. Transfer Pricing Guidance From OECD Changes
  • U.S. Will Remain Engaged In OECD Tax Work: IRS Official
  • OECD Resuscitates Work On Taxing Digital Transactions
  • South Korea Kicks Off Global Tax, Profit Reporting
  • Reporting Form Gives IRS Auditors New Lens for U.S. Groups
  • Transfer Pricing ‘Master File’ Must Bow to Countries’ Rules
  • Companies Root for IRS In Race on Tax Data Exchange
  • An Analysis of the OECD’s Discussion Draft on Profit Splits
  • Cross-Border Hybrid Mismatch Arrangements in a Post-BEPS World: U.S. and EU Perspectives
  • Additional Guidance on the Attribution of Profits To Permanent Establishments—A Welcome Development
  • Belgian Transfer Pricing Rules Go Beyond OECD Recommendations