Base Erosion and Profit Shifting (BEPS)

A Clear Perspective, from Every Angle

Multinational corporations and governments are preparing for international tax reform now that the OECD has completed the G20 BEPS initiative.

Many tax authorities are actively working to develop supporting legislation that will take effect in the coming months. New global tax requirements will result in the need for worldwide standardization of data collection and processes, centralized control, up-to-date monitoring of global transfer pricing legislation updates, and accurate risk assessment.

With a clear perspective, you can see all the details from every angle. Thomson Reuters solutions empower you with up-to-date knowledge, analysis and documentation tools to respond, comply, and advise as new laws and standards are passed on a country-by-country basis.

The U.S. CbC reporting requirements are here – are you prepared?

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BEPS Basics

Why should my organization be concerned about BEPS?

BEPS will result in a fundamental transformation of the global tax regulatory landscape. Because the OECD is not a government, it will require the tax authorities at countries around the world to pass laws and regulations to support the BEPS Action Plan and compel companies to comply with those rules. As a result, countries will pass domestic tax laws and sign on to treaties and other multinational agreements to support the Action Items as they see fit.

As this transformation occurs, consequences for non-compliance will become more costly, onerous and time consuming, and may result in media scrutiny. As robust and consistent tax documentation becomes a requirement, you will want to ensure your organization optimizes its current processes to minimize risk and maintain your reputation.

What is BEPS?
Why should you act now in preparing a BEPS strategy?

As countries pass domestic legislation in support of BEPS, changes to the international tax reporting landscape will present new challenges for multinational corporations and their advisors, requiring time, planning and resources to implement the necessary processes to ensure compliance.

The best defense is to implement research and technology tools that will allow you to act early and with confidence, giving your tax department the support they need to demonstrate their position. Acting early can help alleviate increased pressures and risks on tax departments and finance operations, as MNCs will need to deliver transparent BEPS reporting to required authorities with efficiency, accuracy, and reduced risk of audit.

What are the benefits of leveraging transfer pricing technology in a post-BEPS world?

Transfer pricing documentation is already no easy feat. As the BEPS Action Plan is finalized, strenuous and evolving requirements will necessitate transparency to underlying data and a consistent policy of value creation. With information sourced from various functional groups and locations, technology serves as a central repository for data collection, consolidation, and consistent reporting. Leveraging technology enables you to dedicate time to transfer pricing planning, value chain transformation, and more to address demanding tax authorities in the new, transparent transfer pricing environment.

BEPS Action Items

Action 1: Challenges of digital economy
Action 2: Hybrid mismatches
Action 3: CFC rules
Action 4: Excessive interest deductions
Action 5: Harmful tax practices and transparency
Action 6: Treaty Abuse
Action 7: PE avoidance
Action 8: Transfer pricing — intangibles
Action 9: Transfer pricing — risk and capital
Action 10: Transfer pricing — high-risk transactions
Action 11: Collect and analyze BEPS data
Action 12: Disclosure of aggressive planning arrangements
Action 13: Transfer pricing documentation
Action 14: Dispute Resolution
Action 15: Multilateral BEPS instrument

Preparing for BEPS

How are global jurisdictions and multinational corporations reacting to and preparing for BEPS? Our analysis discusses the impact of emerging legislation, provides insights, and shares best practices to help you comply.

BEPS CBC Reporting for Multinationals

2016 Global BEPS Readiness Survey Report

Download Survey Report
BEPS CBC Reporting for Multinationals

BEPS Filing Requirements for Multinationals Under Country-by-Country Reporting

Download Special Report
Anti-Tax Avoidance Report

European Commission Presents Anti-Tax Avoidance Package

Download Special Report
Action 13 Guide

BEPS Action 13 Guide

Download Guide

2015 Global BEPS Readiness Survey Report

Download Survey Report
BEPS Infographic

2015 Survey Report Infographic

View Infographic

Recent BEPS-Related Blog Posts

Tokyo Tower at sunset. Japan

Japan Adds New Treaty with Belgium to List of Treaties with BEPS Provisions

(10/21/2016) - On October 12, 2016, Japan signed a new income tax treaty with Belgium that would replace the 1968 treaty, as amended by the 1998 and 2010 protocols. The new treaty generally follows the OECD Model Tax Convention, and includes certain BEPS Action 6 and 7 measures.  The treaty will enter into [...] Continue Reading

US treasury department sign in Washington dc building facade

U.S. doesn’t need CbC Master or Local files… for now

(10/18/2016) - Country-by-Country reporting (CbCR) is a cornerstone of BEPS Action 13 on transfer pricing documentation. Hand in hand with that is the provision of a Master File and a Local File. However, the U.S. has not implemented such files because the U.S. IRS says that, for now at least, it does not need Master [...] Continue Reading

Read more BEPS-related blog posts


Tax Talk

These Tax Talk video interviews hail from the 70th Congress of the International Fiscal Association (IFA) – Madrid 2016, and focus on the BEPS Multilateral Instrument (MLI), the Apple/European Commission state ruling and tax certainty.

Robert Stack (3:58)

Deputy assistant secretary of international tax affairs for the United States Treasury, Robert Stack, discusses the BEPS MLI, the EC Apple ruling, US tax reform and the IRS judgement on implementing master and local filing.

Robert Stack (3:58)

Deputy assistant secretary of international tax affairs for the United States Treasury, Robert Stack, discusses the BEPS MLI, the EC Apple ruling, US tax reform and the IRS judgement on implementing master and local filing.

Pascal Saint-Amans (4:49)

Pascal Saint-Amans, tax policy director for the OECD, discusses the controversial Apple ruling in Ireland, the impact of the BEPS implementation process, and the BEPS MLI.  

Porus Kaka (4:07)

IFA president Porus Kaka speaks about uncertainty around BEPS and his concern surrounding country by country (CbC) reporting.

Martin Kreienbaum (4:51)

Martin Kreienbaum, director general of International Taxation for the German Federal Ministry of Finance, discusses the importance of tax certainty for the G20, the upcoming German election and the consistent implementation of BEPS.

IFA Delegate Interviews (8:25)

Axel Threfall, editor-at-large, Reuters, interviews delegates on the floor at IFA Madrid on tax certainty, the BEPS MLI, the Apple/Ireland EC ruling and Brexit.

Philip Baker (4:06)

Following our BEPS MLI Panel discussion, Philip Baker, barrister and international tax specialist for Field Court Tax Chambers in London, defines the MLI, the method of MLI consultation, its flexibility and affect on international tax.

Mary Bennett (3:12)

Following our BEPS MLI Panel discussion, Mary Bennett, tax partner at Baker & McKenzie LLP, speaks on state aid issues in the US, the BEPS MLI and the concern surrounding setting up an alternative to the arm’s length method.

Enrique Diaz Tong (2:42)

Following our BEPS MLI Panel discussion, Enrique Diaz Tong, TP Consulting associate and Lawyer at the Pontificia Universidad Católica of Peru, discusses the challenges of applying the MLI, transfer pricing issues, and automatic exchange of information in Latin America.

Robert Sledz (4:07)

Following our BEPS MLI Panel discussion, our own Robert Sledz, international tax editor/author with the Tax & Accounting business of Thomson Reuters, discusses the BEPS action items of concern, the Apple/EC ruling and resulting tax uncertainty.


Talk BEPS with us at one of these upcoming events

Global Transfer Pricing Forum – New York

September 22-23, 2016
New York, NY

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70th Congress of the International Fiscal Association (IFA)

September 25-30, 2016
Madrid, Spain

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International Tax Roundtable — Los Angeles, CA

October 18, 2016
Los Angeles, LA

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International Tax Roundtable — San Jose, CA

October 19, 2016
San Jose, CA

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International Tax Roundtable — Atlanta, GA

October 25, 2016
Atlanta, GA

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Thomson Reuters is your global partner for international tax compliance challenges. Our BEPS research and technology solutions address your immediate and ongoing needs for country-by-country reporting and other Action Items, while providing a solid foundation for future impact on your organization.

BEPS Global Currents

Checkpoint BEPS Global Currents

With a customizable dashboard of the latest BEPS developments, you can respond proactively to new developments, make strategic plans to minimize impact and ensure you are in compliance with new laws and standards as they are passed.

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BEPS Action Manager


With up-to-date research, valuable risk assessments and intuitive analytics, multinational tax departments can remain current amidst an ever-evolving legislative landscape—and stay ahead of inquiries from various tax administrations.

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