Strategizing Multinational Tax Risks

EY’s Global Alert discusses the upcoming public consultations on BEPS Actions 8-10, and includes country related BEPS initiatives for Australia, France, Honduras, India and Taiwan.

http://www.ey.com/Publication/vwLUAssets/The_Latest_on_BEPS_-_16_March_2015/$FILE/2015G_CM5299_The%20Latest%20on%20BEPS%20-%2016%20March%202015.pdf

The latest updates highlight the pivotal discussions around complex transfer pricing issues including risk recharacterisation (also referred to as non-recognition).  These discussions and final guidelines will set the stage for upcoming controversies, including efforts to avoid double taxation.