Tax policies are constantly evolving and there are a number of complex changes on the horizon that could significantly affect your business.
Grant Thornton’s teams can work with you to help you understand these regulations, develop a strategy tailored to your business’ individual tax needs and manage tax risk around the globe.
Businesses with a footprint in a number of countries will be aware of the variations in tax policies between regions.
In recent years, these tax discrepancies have been at the centre of a public outcry and received huge amounts of media attention. Through aggressive tax planning, some organisations capitalised on these discrepancies and regional variations to avoid corporate tax or reduce their liability. This practice is known as base erosion and profit shifting (BEPS). Although legal in the vast majority of cases, this practice has raised ethical concerns worldwide.
The Organisation for Economic Co-operation and Development (OECD) launched a 15-step action plan to tackle and reduce BEPS, which could lead to major changes in international tax standards.
Action 1: Address the tax challenges of the digital economy
Action 2: Neutralise the effects of hybrid mismatch arrangements
Action 3: Strengthen controlled foreign corporation (CFC) rules
Action 4: Limit base erosion via interest deductions and other financial payments
Action 5: Counter harmful tax practices more effectively, taking into account transparency and substance
Action 6: Prevent treaty abuse
Action 7: Prevent the artificial avoidance of permanent establishment (PE) status
Action 8: Assure that transfer pricing outcomes are in line with value creation/intangibles
Action 9: Assure that transfer pricing outcomes are in line with value creation/risks and capital
Action 10: Assure that transfer pricing outcomes are in line with value creation/other high-risk transactions
Action 11: Establish methodologies to collect and analyse data on BEPS and the actions to address it
Action 12: Require taxpayers to disclose their aggressive tax planning arrangements
Action 13: Re-examine transfer pricing documentation
Action 14: Make dispute resolution mechanisms more effective
Action 15: Develop a multilateral instrument
If you do business across borders, it’s essential you understand these possible changes to tax systems. Having a firm grasp on the OECD’s plans could protect you from reputational damage and also make sure your business is compliant with necessary rules and regulations.
Grant Thornton International Ltd, with input from its member firms and their clients, welcomes the opportunity to comment on the discussion drafts issued by the OECD and the European Commission on future tax legislation. The detailed responses to key areas are available below:
|Additional Guidance on the Attribution of Profits to Permanent Establishments (PDF) (5MB)||Sept 2016||Action 7|
|Common Consolidated Corporate Tax Base (CCCTB) (PDF)||Dec 2015|
|Prevent treaty abuse (PDF) (5MB)||June 2015||Action 6|
|Hard to value intangibles (PDF) (5MB)||June 2015||Action 8|
|Preventing the artificial avoidance of PE status (PDF) (5MB)||June 2015||Action 7|
|Revisions to Chapter VIII of the Transfer Pricing Guidelines on Cost Contribution Arrangements (CCAs) (PDF) (5MB)||May 2015||Action 8|
|Strengthening CFC rules (PDF) (5MB)||
|Draft on the use of profit splits in the context of global value chains (PDF) (5MB)||February 2015||Action 10|
|Interest deductions and other financial payments (PDF) (5MB)||February 2015||Action 4|
|Transfer pricing aspects of cross-border commodity transactions (PDF) (5MB)||February 2015||Action 10|
|Revisions to 'Chapter 1' of the transfer pricing guidelines (PDF) (5MB)||February 2015||Action 8.9 and 10|
|Follow-up work on preventing treaty abuse (PDF) (5MB)||January 2015||Action 6|
|Preventing the Artificial Avoidance of PE Status (PDF) (5MB)||January 2015||Action 7|
|Proposed modifications to Chapter VII of the transfer pricing guidelines relating to low value-adding intra-group services (PDF) (5MB)||January 2015||Action 10|
|Make dispute resolution mechanisms more effective (PDF) (5MB)||
|Transfer pricing documentation and country by country reporting (PDF) (5MB)||February 2014||Action 13|
If you have any questions or would like to find out more about how we can help, check your local Grant Thornton member firm’s website and contact details.