Reforms To International Tax Rules

BACKGROUND

In conjunction with the G20, other States and various interested parties, the Paris-based Organisation for Economic Co-operation and Development ("OECD") is currently in the middle of a major international project under the aegis of the G20 to counter Base Erosion and Profit Shifting ("BEPS"). 

The BEPS project is part of wider developments in the international tax field, including plans for automated exchange of information between tax authorities and efforts to improve transparency on tax matters.  (For example, on 29 October 2014, fifty one tax jurisdictions, including the UK, signed the OECD's Multilateral Competent Authority Agreement, which provides for automated annual exchange of information between tax authorities from, in most cases, September 2017).  Ultimately, the possible impact of the BEPS project is a re-write of many of the principles of international tax which, in turn, could have a significant impact on how, in particular multinational