On October 5, the OECD presented its final package of measures
attacking base erosion and profit shifting.1 Undertaken
at the request of the G-20 leaders, the efforts to address BEPS are
based on the G-20 and OECD's BEPS action plan from July 2013,
which identified 15 actions to end what is perceived by the OECD as
unacceptable international tax planning.
On four prior occasions since the advent of the BEPS project in
February 2013, we have offered both a general and a Canadian
perspective on various aspects of this unprecedented attack on
international tax management (including strategic planning and
structuring) by multinational enterprises.2 The release
of the final reports gives occasion to revisit our prior views and
offer new commentary on the BEPS initiative.
