Solving gaps between tax rules of the several countries
Purpose of this project is to solve gaps between tax rules of the several countries used by multinationals to legally transfer their benefits to countries with a minimal or no taxation. BEPS is today supported by around 90 countries. Launched in 2013, the OECD /G20 BEPS leads to a release of 15 final reports delivered in October 2015.
Principles are declined in fifteen actions defined at the beginning of the project in 2013. The objective is to provide governments with domestic and international instruments to address tax avoidance, ensuring that profits are taxed where economic activities generating the profits are performed and where value is created. These fifteen actions are:
1. Digital Economy
2. Hybrids
3. CFC Rules
4. Interest Deductions
5. Harmful Tax Practices
6. Treaty abuse
7. Permanent Establishment Status
8-10. Transfer Pricing
11. BEPS Data Analysis
12. Disclosure of Aggressive Tax Planning
13. Transfer Pricing Documentation
14. Dispute Resolution
15. Multilateral instrument
Impacts of this project are based on three principles:
Increase coherence:
Standards rules have been elaborated to:
Best practices on mandatory communication of information was also defined and exchanges of information on some tax rulings set up.
Reinforce regulatory on substance:
Ensure more transparency and legal protection:
OCDE’s opinions are only recommendations which then need to be transposed into national laws.
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Regulated or
Unregulated 