Strategizing Multinational Tax Risks

EY’s Global Tax Alert provides a succinct summary of the latest OECD and BEPS developments, including:

• G20 and exchange of information upon request standard
• Multilateral instrument, 68 countries moving forward
• Peer reviews on BEPS 4 minimum standards:
  • Action 5, harmful tax practices
  • Action 6, treaty abuse
  • Action 13, country-by-country reporting (CbCR)
  • Action 14, dispute resolution
• Action 5 peer reviews of preferential tax regimes
• Action 13, CbCR exchange relationships; important for US MNE’s and similar jurisdictions without obligatory 2016 reporting
• MAP peer reviews
• Discussion drafts on profit splits and attribution of profits re: PE’s; comment period to Sept. 15, 2017
• Branch mismatch forthcoming revisions
• Common reporting standard
• Digital taxation

OECD is still very busy, with a plethora of BEPS follow-up and other activities, although there seems to be continuing flexibility to gain collaboration that will also lead to added complexity and disputes.

Click to access 2017G_04094-171Gbl_OECD%20provides%20updates%20on%20tax%20activities%20in%20Tax%20Talk%20webcast.pdf