Action Plan on Base Erosion and Profit Shifting
(2013)Abstract
Key Elements 1 to 115 of the BEPS action plan (summer 2013).
1. Adress the tax challenges of the digital economy: Analyse der Spezifik der digitalen Wirtschaft für die Besteuerung
(i) Establishing international coherence of corporate income taxation
2. Neutralise the effects of hybrid mismatch arrangements
3. Strengthen "Controlled Foreign Company Rules"
4. Limit base erosion via interest deductions and other financial payments
5. Counter harmful tax practices mor effectively, taking into account transparency and substance
(ii) Restoring the full effects and benefits of international standards
6 – Prevent treaty abuse
7 – Prevent the artificial avoidance of PE status
8 – Assure that transfer pricing outcomes are in line with value creation: intangibles
9 – Assure that transfer pricing outcomes are in line with value creation: risks and capital
10 – Assure that transfer pricing outcomes are in line with value creation: other high-risk transactions
11 – Establish methodologies to collect and analyse data on BEPS and the actions to address it
(iii) Ensuring transparency while promoting increased certainty
and predictability
12 – Require taxpayers to disclose their aggressive tax planning arrangements
13 – Re-examine transfer pricing documentation
14 – Make dispute resolution mechanisms more effective
(iv) From agreed policies to tax rules: the need for a swift
implementation of the measures
15 – Develop a multilateral instrument
These tasks ought to be accomplished by summer 2014 up to winter 2015
Description
Action Plan on Base Erosion and Profit Shifting - BEPSActionPlan.pdf