BEPS plan

The action plan of Base Erosion and Profit Shifting (BEPS) was developed by the OECD and approved by the G20 to enable participating countries to combat the withdrawal of profits to low-tax jurisdictions. It provides for a number of tools designed to assist control over the distribution of activities and profits within multinational corporations. Some of the BEPS actions (e.g. Controlled Foreign Companies rules, interest deductibility limitation, general anti-avoidance rules) are being implemented at the national level. The other however require intergovernmental cooperation in the field of international taxation.  The Multilateral Convention implementing BEPS plan was signed in June 2017 by 68 countries and several more states joined at a later stage. The Convention affects the existing tax treaties concluded bilaterally between the participating states to include rules limiting the application of tax benefits. 

Certain changes in the national tax regimes resulting from the ratification of the Convention are expected, including restrictions on indirect benefits applied to gains from alienation of shares or interests in property rich entities; provisions to prevent artificial avoidance of permanent establishment status; regularization of taxation of dual resident entities. Taxpayers are recommended to develop awareness and thorough understanding of the BEPS plan when structuring their international business affairs.

MP Part can support in assessing the implication of BEPS action plan on your business and private assets. Our offer includes:

  • clarification of the relevant provisions, their application and consequences;
  • analysis of BEPS impact over the client’s asset structure;
  • evaluation and execution of the restructuring opportunities.

Please get in touch with us with any questions that relate directly or indirectly to BEPS action plan and its implementation in the applicable tax legislation.