The Organization for Economic Cooperation and Development (OECD)
has recently issued a 15 point action plan on base erosion and
profit shifting (BEPS). The plan aims to "effectively
prevent double non-taxation" and to ensure that no or low tax
jurisdictions will not be able to continue with practices that
"artificially segregate taxable income from the activities
that generate it".
It seems that the action plan of the OECD will have a huge
impact on worldwide transfer pricing and these actions must be
carefully considered as it may have a major impact on how
multinational groups operate.
Tax challenges of the digital economy
The growth of a digital economy has been identified as one of
the major issues that have to be addressed, taking into account its
impact on BEPS. It is important that an internationally
consistent system has to be implemented to identify the
profitability of digital activities. The intangible nature of
digital activities makes it harder
