International Tax Measures - March 22, 2016

Base erosion and profit shifting ("BEPS") is the term used to refer to tax planning arrangements undertaken by multinational enterprises ("MNEs") that exploit the interaction between domestic and international tax rules to minimize taxes. Typically, BEPS involves an effective transfer of income from a higher tax jurisdiction to low or no-tax jurisdictions.

The Organization for Economic Cooperation and Development (the "OECD") has worked on guidelines for countering BEPS for a number of years, releasing an initial BEPS report in 2013 at the request of the governments of The Group of Twenty (the "G20"). On October 5, 2015, the OECD presented a final package of the OECD/G20 BEPS project's 15 point action plan ("BEPS Project"), which includes finalized guidance on transfer pricing, neutralizing the effects of hybrid mismatch arrangements, preventing the granting of treaty benefits in inappropriate circumstances and developing a multilateral instrument to modify