Base Erosion and Profit Shifting

Base Erosion and Profit Shifting (BEPS):

We will be updating this page as new information is released regarding BEPS and the implications for intercompany financing including country by country reporting. Please contact us if you wish to discuss any of the guidance offered to date and what implications this guidance may have on your current intra-group financing structure(s). Further work on transfer pricing guidance on financial transactions will be undertaken by the OECD during 2016 and 2017.

OECD Releases:

Final Report on Action 4, Limiting Base Erosion Involving Interest Deductions and Other Financial Payments (October 5, 2015)
http://www.oecd-ilibrary.org/docserver/download/2315311e.pdf?expires=1447115262&id=id&accname=guest&checksum=37D11EDF83B964C822D008FFD4D80229
Additional Comments Received on Public Discussion Draft (February 19, 2015)
http://www.oecd.org/ctp/aggressive/additional-public-comments-action-4-interest-deductions-other-financial-payments.pdf
Comments Received on Public Discussion Draft:
BEPS Action 4: Interest Deductions and Other Financial Payments, Part 1, February 11, 2015 http://www.oecd.org/tax/aggressive/public-comments-action-4-interest-deductions-other-financial-payments-part1.pdf
Comments Received on Public Discussion Draft: BEPS Action 4:
Interest Deductions and Other Financial Payments, Part 2, February 11, 2015
http://www.oecd.org/ctp/aggressive/public-comments-action-4-interest-deductions-other-financial-payments-part2.pdf
OECD Public Discussion
Draft BEPS Action 4: Interest Deductions and Other Financial Payments
http://www.oecd.org/ctp/aggressive/discussion-draft-action-4-interest-deductions.pdf

Quick Links

Recent Publications

Intercompany Financial Transactions:

Factors to Consider In Analyzing the Impact of Implicit Support
(Bloomberg BNA: 20/2/2014)
Transfer Pricing and Intra-group Cash Pooling:

(Bloomberg BNA: 14/2/2011)
Intercompany Financial Transactions:

Selecting Comparable Data
(Bloomberg BNA: 22/4/2010)

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