You may withdraw your consent to cookies at any time once you have entered the website through a link in the privacy policy, which you can find at the bottom of each page on the website. Presumably, Pillar 1 would be applied to an MNE prior to applying Pillar 2. [58] The project is intended to prevent multinationals from shifting profits from higher- to lower-tax jurisdictions. BEPS Action Item 13, in particular, aims to transform transfer pricing documentation, forcing multinational corporations to reconsider how transfer pricing details are reported to local tax authorities as well as worldwide with country-by-country reporting. BEPS hubs (or Conduit OFCs) strongly deny they are corporate tax havens, and that their use of IP is as a tax avoidance tool. The OECD’s BEPS policies are being designed to create a framework that allows this to happen. How do you create customer intimacy without proximity? They are also striking different enforcement postures, which is contributing to a riskier environment for tax in general and transfer pricing in particular. KPMG report: BEPS Action 13, country implementation - 2 October 2020 [PDF 2.1 MB]. It came into force in July 2018. For a more detailed discussion of the issues that the Pillar 2 GloBE creates, please consult our detailed comments to the OECD. The Pillar 2 consultation document suggests that consolidated financial statements could be used to determine the tax base for global income. The implementation of the BEPS action … Treaty provisions regarding PE status (BEPS action 7). [12][13] The effect of BEPS tools is most felt in developing economies, who are denied the tax revenues needed to build infrastructure. Useful Links. [49][50] None of these new BEPS tools have been as yet proscribed by the OECD. BEPS Action Item 13, in particular, aims to transform transfer pricing documentation, forcing multinational corporations to reconsider how transfer pricing details are reported to local tax authorities as well as worldwide with country-by-country reporting. If you would like to discuss any of the issues in more detail or if you would like assistance modelling how the proposals may affect your business, please contact one of the people listed or speak to your local Grant Thornton office. Preparing for BEPS. This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. Services are delivered by the member firms. Ireland was the first major corporate tax haven to be "blacklisted" by a G20 economy: Brazil in September 2016. Ireland's "CAIA tool"). The government is finding out", "€600 billion and counting: Why high-tax locations let tax havens flourish", "The Policy Failure of High-Tax Countries", "Gimme shelter - A survey of globalisation and tax", "FISCAL PARADISE: FOREIGN TAX HAVENS AND AMERICAN BUSINESS", "Action Plan on Base Erosion and Profit Shifting", "TAX ANNEX TO THE SAINT PETERSBURG G20 LEADERS DECLARATION", "What's Wrong With Intercompany Accounting? [71] For example, by accepting Irish tangible, and intangible, capital allowances in the GILTI calculation, Irish BEPS tools like the "Green Jersey" enable U.S. multinationals to achieve U.S. effective tax rates of 0–3% via the TCJA's foreign participation relief system. “There was a lot of anxiety about what a post-BEPS world would look like a couple of years ago,” says Peter Griffin, EY Global Transfer Pricing Leader. The OECD has issued 15 Action Items to address the main areas where they feel companies have been most aggressively accomplishing this shifting of profit — addressing the digital economy, treaty abuse, transfer pricing documentation, and more. The 2012 G20 Los Cabos summit tasked the OECD to develop a BEPS Action Plan,[56][57] which 2013 G-20 St. Petersburg summit approved. © 2020 EYGM Limited. Your online resource to get answers to your product and industry questions. After a slow and tentative start, the OECD’s push for a solution on how to allocate and tax the profits from digital business is gathering momentum.

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