Base Erosion and Profit Shifting: OECD releases its first measures


On 16 September 2014, the Organisation for Economic Co-operation and Development (OECD) released its first recommendations for a coordinated international approach to combat tax avoidance by multinational enterprises. These recommendations are set out under the OECD-G20 Base Erosion and Profit Shifting (BEPS) Project which aims at tackling practices which erode the tax base of companies and artificially shift profits to low or no-tax jurisdictions.

In this context, OECD published the 7 first reports of its Action Plan to help countries to:

  • Address tax challenges of the digital economy (Action 1);
  • Neutralise hybrid mismatch arrangements (Action 2);
  • Counter harmful tax practices more effectively (Action 5);
  • Prevent the granting of treaty benefits in inappropriate circumstances (Action 6);
  • Address transfer pricing issues for intangibles (Action 8);
  • Improve transfer pricing documentation (Action 13); and
  • Use of a multilateral tax treaty to implement all BEPS measures (Action 15).

This BEPS toolkit was presented to G20 Finance Ministers at their meeting on 20-21 September in Cairns, Australia.

Through our Bird & Bird network, we are able to offer you assistance, and answer your questions regarding these new measures.