Base Erosion Profit Shifting (BEPS)

BEPS refers to tax planning strategies that exploit gaps, mismatches and loopholes in tax rules and tax treaties in order to make profits “disappear” for tax purposes or to shift profits to locations where there is little or no real activity but where the taxes are low, resulting in little or no overall corporate tax being paid. To date, these tax planning strategies are legitimate and hard to combat by jurisdictions.

Amicorp can help you to address this challenging new BEPS environment:

  • Determining which of the BEPS action plans may affect your structure;
  • Improving factual and economic substance and alignment of taxation with economic activities and value creation; and
  • Complying with some of the Transfer Pricing documentation that will be required (i.e. master file, local file, country by country report)

For more information on how to respond to the global BEPS project, and take advantage of Amicorp’s services, please contact your Amicorp Account Manager, Sales Manager or your nearest Amicorp office.

  • Awareness
  • Health Checks
  • Improvements
  • Alternative Solutions
  • Monitoring
Fifteen BEPS action plans

The debate over BEPS tax planning strategies has now reached the front pages of the newspapers and also the agendas of both OECD members and non-OECD countries governments. Upon request of the G20, the OECD published in July 2013 a document identifying the 15 Actions through which these BEPS tax strategies can be tackled. These 15 Action Plans are focused on:

  • Establishing coherence in international taxation;
  • Aligning taxing rights with substance; and
  • Improving transparency

In essence, the BEPS project attempts to align taxation with activity. Companies should be taxed in the country or countries in which the activities take place.

Recommendations to modify domestic law and tax treaties
Impact on many tax planning structures