Page 39 - UUBO Deal Academy 2020 - Materials

BEPS in a Nutshell

1 2 3 • The BEPS Action Plan was initiated by the G20
Address the challenges of Neutralise the effects of Strengthen CFC rules
the digital economy hybrid mismatch through the OECD to tackle aggressive tax
arrangements avoidance through base erosion and profit

4 5 6 shifting (BEPS)
Limit base erosion via Counter harmful tax Prevent treaty abuse
Interest Deductions and practices taking into • Main objectives are:
other financial payments account transparency
and substance • Substance
7 8 9 • Coherence
Prevent the artificial Ensure TP outcomes are Develop TP rules to
avoidance of Permanent in line with value creation prevent the transfer of • Transparency
Establishment status by preventing the risks among, or allocating
unnecessary movement excessive capital to group • Certainty
of intangibles among members
group members • Involving non-member countries through the

10 11 12 OECD Inclusive Framework (IF) including the
Develop TP rules to Establish methodologies Require taxpayers to
prevent unnecessary high to collect and analyse disclose their aggressive African Tax Administration Forum (ATAF)
risk transactions data on BEPS and the tax planning
actions to address it arrangements • Setting minimum standards for the IF

13 14 15
Re-examine TP Make dispute resolution Develop a multilateral • Ensuring implementation using multilateral
documentation mechanisms more instrument instruments
effective

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