Strategizing Multinational Tax Risks

The Asia-Pacific Regional Network on BEPS discussed the impact of BEPS on their region in its meeting on 12-13 February 2015, with over 50 senior tax officials from 21 jurisdictions and international organisations attending.  Attendees included the Asian Development Bank, IMF, US Agency for International Development (USAID) and the Study Group on Asian Tax Administration and Research (SGATAR).

Twelve direct participants in the BEPS project consist of Australia, Japan, Korea, New Zealand, China, India, Indonesia, Malaysia, Singapore, Bangladesh, Philippines and Vietnam.  The discussion summary is included for reference:

Click to access beps-regional-network-asia-co-chairs-summary-of-discussions.pdf

Discussion Summary:

• Participants supported the cooperative and inclusive process for developing countries to support the OECD/G20 strategy.
• All stakeholders, including MNE’s, should be engaged to address BEPS solutions.
• Recognition of uncoordinated regional efforts addressing interest deductibility (Action 4), PE (Action 7), transfer pricing issues (Actions 8-10), and transfer pricing documentation (Action 13).
• The introduction of toolkits, further support, and assistance is welcomed, including their participation in the OECD dialogue process.
• Further guidelines on dispute resolution were requested by business and NGO representatives.
• Future involvement will focus on additional engagement, participation and collaboration with various partners.
• Next meeting is scheduled for 16-18 March 2015.

As the BEPS project proceeds to finalize its deliverables this year, the input of this organization and other interested parties will provide a limited window of opportunity to share views and practical suggestions to ensure consistency for taxpayers and tax administrations regionally and globally.  Accordingly, monitoring (including active participation in) future developments will be critical to form Best Practices for taxpayers and tax administrations.

Most importantly, it will be critical to ensure regional participants do not execute unitary legislation prior to release of the final OECD guidelines to ensure the BEPS process is successful.  The timing of such initiatives should also be a priority for the Asia-Pacific Network, its participants and other countries around the world. 

Related posts:

1. OECD Tax Inspectors Without Borders (TIWB) and Toolkit: 30 January 2015
2. Creation of task force and prior meeting of SGATAR: 1 December 2014
3. OECD BEPS Strategy for Developing Countries: 13 November 2014