On 5 October 2015, the OECD published the final reports of the OECD/G20 Base Erosion and
Profit Shifting ("BEPS") project, which consist of a
package of measures for a co-ordinated international approach to
reform the international tax system. This package will be discussed
by the G20 ministers of finance on 8 October 2015. The combination
of proposed anti-abuse rules and increased transparency will have
significant implications for (groups of) companies operating in
multiple jurisdictions.
General comments
The final BEPS package includes and consolidates the final 2014
deliverables of the OECD BEPS Action Plan that identified 15 action
points (the "Actions"). Although the final BEPS package
is intended to be comprehensive, the level of proposed commitment
varies per proposed measure. The OECD/G20 member states commit to
consistent implementation in the areas of preventing tax treaty
shopping, Country-by-Country Reporting, combatting harmful tax
practices and
