Worldwide reactions – BEPS recommendations

We are seeing an astounding amount of activity amongst various countries and groups as they consider the recommendations made under the OECD’s Base Erosion and Profit Shifting (BEPS) project.

• G20 leaders have endorsed the recommendations at the G20 summit in Turkey this month.
• Australia is “firmly on the right track” according to the Treasurer, in supporting the recommendations made, and has recently introduced a bill into Parliament called the Multinational Anti-Avoidance Law.
• Ireland has drafted legislation for country-by-country reporting which is consistent with Action 13 of the BEPS project and which is applicable to MNCs with a consolidated group turnover of more than EUR750 million with the ultimate parent tax resident in Ireland.
•  New Zealand has added the BEPS action plan to its 2016 work programme, however, has already stated its strong support for the action plan.
• The United States is considering revising its Model tax treaty with country-by-country reporting on the IRS’ business plan.
• Mexico is taking BEPS-inspired actions with regard to certain related party payments, tax treaty benefit claims, new information returns and limiting the creation of permanent establishments
• Brazil is reviewing its transfer pricing and CFC rules.
• South Korea is tightening its thin capitalization rules, increasing penalties for tax fraud and looking at a VAT on digital services via foreign open markets.