Strategizing Multinational Tax Risks

UK and Australia have formed a joint working group to develop initiatives re: “diverted profits” by MNE’s.

A copy of the press release is attached for reference:

http://jbh.ministers.treasury.gov.au/media-release/030-2015/

The press release cites the urgency of such legislation, while also stating that such initiatives will be consistent with the OECD BEPS Actions.

The UK’s new tax still has more questions than answers, and it is hopeful that Australia and members of the G20 will await OECD’s final guidance on BEPS initiatives and align any new tax with comprehensive documentation prior to issuance.  Additionally, it will be interesting to note the trend away from citation of the well recognized arm’s length principle toward a concept of economic value and significant people functions.