OECD

The work of the OECD is based on a BEPS Action Plan endorsed by the G20 in July 2013.  15 key areas were identified to be addressed by 2015; with 7 actions delivered in September 2014 in an interim form.   These 2014 outputs are consolidated with the remaining 2015 deliverables delivered to the G20 Finance Ministers in October 2015, together with a plan for the follow-up work and a timetable for their implementation.

2015 Deliverables

• Action 3: Strengthen CFC Rules
• Action 4: Limit Base Erosion via Interest Deductions and Other Financial Payments
• Action 7: Prevent the Artificial Avoidance of PE Status
• Action 9: Assure that Transfer Pricing Outcomes are in Line with Value Creation/Risks and Capital
• Action 10: Assure that Transfer Pricing Outcomes are in Line with Value Creation/Other High-Risk Transactions
• Action 11: Establish Methodologies to Collect and Analyse Data on BEPS and the Actions to Address It
• Action 12: Require Taxpayers to Disclose their Aggressive Tax Planning Arrangements
• Action 14: Make Dispute Resolution Mechanisms More Effective

2014 Deliverables (Released in September 2014)

• Action 1: Address the Tax Challenges of the Digital Economy
• Action 2: Neutralise the Effects of Hybrid Mismatch Arrangements
• Action 5: Counter Harmful Tax Practices More Effectively, Taking Into Account Transparency and Substance
• Action 6: Prevent Treaty Abuse
• Action 8: Assure that Transfer Pricing Outcomes are in Line with Value Creation/Intangibles
• Action 13: Re-examine Transfer Pricing Documentation
• Action 15: Develop a Multilateral Instrument

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