Welcome to the Chartered Accountants Ireland BEPS centre

“Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid. BEPS is of major significance for developing countries due to their heavy reliance on corporate income tax, particularly from multinational enterprises (MNEs)”.



A discussion draft on financial transactions dealing with follow-up work to Actions 8-10 ("Assure that transfer pricing outcomes are in line with value creation") of the BEPS Action Plan was published by the OECD recently. The 2015 report on BEPS Actions 8-10 mandated follow-up work on the transfer pricing aspects of financial transactions.  The discussion draft aims to clarify the application of the principles included in the 2017 edition of the OECD Transfer Pricing Guidelines. The draft also addresses specific issues related to the pricing of financial transactions such as treasury function, intra-group loans, cash pooling, hedging, guarantees and captive insurance. Interested parties are invited to send their comments on this discussion draft, and to respond to the specific questions included in the boxes, by 7 September 2018 by e-mail to TransferPricing@oecd.org.

Jul 09, 2018

Ministers and senior officials from Kazakhstan, Peru, the United Arab Emirates and Estonia recently signed the BEPS Multilateral Convention bringing the total number of jurisdictions in the Convention to 82. This Convention updates the existing network of bilateral tax treaties which aims to reduce opportunities for tax avoidance by multinational enterprises. The Convention will enter into force on 1 July 2018 for five of the jurisdictions (Austria, the Isle of Man, Jersey, Poland and Slovenia) that signed last year.  The Convention is the first multilateral treaty of its kind, allowing jurisdictions to integrate results from the OECD/G20 BEPS Project into their existing networks of bilateral tax treaties. The OECD/G20 BEPS Project aims to close the gaps in existing international rules that allow corporate profits to be artificially shifted to low or no tax environments, where companies have little or no economic activity according to the OECD.

Jul 02, 2018
Tax International

The OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method, under BEPS Action 10. The new guidance for tax administration on the application of the approach to hard-to-value intangibles is designed to provide a common understanding and practice among tax administrations on how to apply adjustments resulting from the application of this approach.  The revised guidance on the profit split method is developed as part of Action 10 of the BEPS Action Plan. This guidance has been formally incorporated into the Transfer Pricing Guidelines, replacing the previous text on the transactional profit split method in Chapter II.

Jun 26, 2018