Global Focus on BEPS

BEPS by Action

  • Share

Coherence

Harmful or inappropriate use of international tax legislation to obtain unintended tax benefits

Action 2
Hybrids

Action 3
CFC rules

Action 4
Interest deductions

Action 5
Harmful tax practices

Substance

Mismatches where profits are being taxed vs. where people responsible for generating these profits are located

Action 6
Treaty abuse

Action 7
Permanent
establishment
status

Actions 8-10
Transfer pricing

Transparency

Provide tax authorities information to carry out audits better and determine if “fair share” of taxes are being paid

Action 11
BEPS data analysis

Action 12
Disclosure of aggressive tax planning

Action 13
Transfer pricing documentation

Action 14
Dispute resolution