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10 mins on OECD's BEPS project. (BEPS (Most affected (Multinational…
10 mins on OECD's BEPS project.
BEPS
Est 1986
Where to invest and structure GBO
International tax rules
New law changes
Most affected
Multinational increased in tax burden 84% of the total WE
Timeframe
October 15, assessing impact on operations.
Surprising takeaway
Detail by country by country tax, visible financial reports.
Who is driving them?
Five basic groups
Coherence - removing gaps
Substance - aligning taxes rights
Transparency - tax reporting and disclosure
The digital economy
Implement certain BEPS recommendations
Globally about tax issues
70% are concerned by increase
67% competitive & efficient tax system
54% governments has not been effective
53% governments implementing more tax policies.
Reasoning
Transaction flows
Sales
Loans
Licenses
Tax efficiencies
Tax incentives
Economic growth
Social objectives
Invest or structure operations in particular ways.
Some countries provide preferential tax treatment for manufacturing
Taxing the supply chain
Different countries vary
Substance & tangible assets
More business planning on tax considerations
Specific rule changes
Transfer pricing: key component and tax compliance
Intangibles
intellectual property
Risk
Commodities
Low value -adding services
Documentation
Country by country finance reporting
Hybrid
Tax arrangements
Tax treaties
Interest
Permanent establishment
Local -country income taxes.
Other reports
Long-term effects
Tax incentives
Harmful tax practices.
Taxing digital commerce
Value- added taxes
Global tax treaty
Disclose aggressive tax planning
Controlled foreign corporations.
Tax dispute resolution between countries
Tax planning
Treasury arrangements
operations
Increase in data & reporting
Tax reporting system
Disclose
Country by county reporting
Pre-tax profits and taxes paid
Number of empolyees
Revenues
Taxes paid
Local entities
Mater file
Capital invested
Tax changes
Local file
Business info
Security of transmission
Storage
Handing
Reduce double taxation
Cost & corporate structures
intercompany flows