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.
