The Final OECD BEPS Tome Has Arrived

Remarkably on schedule, the OECD this week issued a comprehensive and integrated set of measures to attack base erosion and profit shifting (BEPS) on a global basis. Comprising 15 "Actions" on central issues such as transfer pricing, country-by-country reporting and transfer pricing documentation, treaty abuse, preferential tax regimes, permanent establishments, hybrid arrangements, cross-border dispute resolution, and implementation, this massive undertaking achieved consensus among all OECD and G20 countries on most major issues. Developing countries and other international and regional tax organizations also participated actively.

Per the Foreword to the final reports, "The BEPS package of measures represents the first substantial renovation of the international tax rules in almost a century." However one characterizes the outcome – there will be many different views – the product cannot be ignored and will have significant impacts on planning and operation of