Significant Progress Made On The OECD’s BEPS Action Plan

This Legal Update is the second in a series that Mayer Brown Tax lawyers are publishing on key developments at the national and international levels related to the Organisation for Economic Co-Operation and Development's ("OECD") Action Plan on Base Erosion and Profit Shifting (the "BEPS Action Plan"). At the core of the BEPS Action Plan is the perceived problem of "double non-taxation" and the intense political pressure from the G-20 and its member states for the OECD to take decisive and internationally coordinated action.

As we described in our first Legal Update on this topic, dated July 30, 2013, the BEPS Action Plan sets forth 15 proposals for specific actions ("action items") that the OECD intends to complete during the next two years. These action items contemplate potentially significant changes to the international tax system in areas such as transfer pricing, the permanent establishment threshold, and hybrid entities and instruments, as well as overhauls