Economic substance and transparency - the new drivers in today’s tax environment – are now more than ever the name of the game. While tax structures are being scrutinized globally, clients are looking for knowledgeable and trusted partners to offer them one-stop-shop solutions in a 360º service.

Base Erosion and Profit Shifting ("BEPS") refers to tax planning strategies that exploit gaps in tax rules, leading to artificially shifting profits to low or no-tax locations where there is little or no economic activity or eroding tax bases through deductible payments. The BEPS measures recommended by the OECD are being implemented in 130+ countries that are part of the inclusive framework.

Recently, the G20 and Inclusive Framework also endorsed the two-pillar global tax reform that deals with the tax challenges arising from digitalization and introducing a global minimum tax. Our global presence and BEPS-compliant services make us well-placed to assist family businesses and large international corporates crossing borders.

With a BEPS health test, Amicorp can help identify outdated structures and adapt these to the new international transparency and economic substance drivers while complying with the latest regulatory standards and respecting business needs.

To keep our clients BEPS compliant, we can also support the multinational structures by migrating entities to another cost-efficient jurisdiction where the economic substance may be available. We look to optimize organization and operations with a simplified and robust structure adapted to the new BEPS governance, substance, and good practices rules.

Our services include:

Assurance: Impact assessment report

  • BEPS health test: analysis of the corporate structure, business reasons, and substance identifying the impact/risk of the latest changes in regulations and
  • Providing recommendations on improvements of the existing structure or alternative structure solutions.

Improvements: Substance & Governance

  • Improve substance: Implement Enhanced Corporate Services ("ECS") to move towards more corporate robustness and solidness.
  • Improve governance: nominate personal directors to the Board and mitigate risks and conflicts of interest by separating ownership and management.

Continuous monitoring

  • Generate business insights and opportunities with strategic planning.
  • Find efficiencies in costs, financing alternatives, and processes.
  • Establishing investment funds, venture capital, trusts, foundations, and securitization vehicles.
  • Support in issuing bonds or listing to stock exchanges.
  • Focus on your core business and delegate the non-core to Amicorp Group

Alternative structuring solutions

  • Continuously monitor legislation developments.
  • Regular evaluation of the structure if it is tax compliant.

Make a plan for a successful transition to the next generation

  • Succession planning.
  • Governance planning.

For more detailed information on responding to the global BEPS project and taking advantage of Amicorp's services, please contact an Amicorp office near you or your local Amicorp Account Manager.

Our professionals

Eric Boes, Global Head – Regulatory Reporting and Tax Compliance Services e.boes@amicorp.com

+31 20 578 8388