Base Erosion and Profit Shifting (BEPS)

Base Erosion and Profit Shifting (BEPS)

The global campaign to address tax base erosion and profit shifting (BEPS) is in full swing, dramatically changing the Tax landscape.


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Simon Schaadt

Tax Partner



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BEPS Advisors


In the past two years, there has been an unprecedented and substantial focus on the international tax agenda from the media, politicians, public authorities and the general public. Governments have engaged the OECD to address base erosion and profit shifting ("BEPS"). As the timeline is strict and the published action plans is ambitious, now is the time for senior management to address the impact of the new tax landscape on their organisation. The Danish tax authorities have already identified BEPS-related initiatives in their 2015 action plan and used BEPS discussion drafts in recent transfer pricing audits.

Why now?

  • To proactively solve discrepancies between your tax strategy and the BEPS initiatives
  • To be prepared for the higher transparency requirements which will lead to higher scrutiny of transfer pricing in the future
  • To be prepared for the Danish tax authorities requesting BEPS-related information already now as they are already implementing BEPS initiatives
  • To be prepared for some tax structures potentially being challenged post-BEPS

Impact of BEPS

The BEPS project will lead to increased business transparency, consistency in international tax rules and higher documentation requirements.


How can we help?

In the light of these developments, we wish to help you address the new tax landscape and any present risks that can be mitigated before the implementation of BEPS. We can help to:

  • identify main risks and possibilities related to the BEPS deliverables;
  • ensure that design data extractors comply with the requirements for Country-by-Country reporting;
  • provide heat map of the countries, structures and functions to focus on;
  • perform thorough value chain mapping to ensure alignment between value creation and profit allocation;
  • assess your organisation’s readiness to the new tax agenda and take necessary action;
  • assist in the preparation of a BEPS readiness report, including an assessment of transfer pricing policies, processes and controls and of the current state of the documentation package.

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