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Businesses’ tax policies and the amount of tax they pay are increasingly coming under close governmental and public scrutiny. The Organisation for Economic Co-operation and Development (OECD) has responded to these concerns with its coordinated Action Plan for the Base Erosion and Profit Shifting (BEPS) project. The question is not whether the OECD's BEPS project will affect multinational companies, but when and to what extent.



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The OECD Plan sets forth 15 actions to address BEPS in a comprehensive international and coordinated way. Basically, the idea is to amend the prevailing international tax standards with a new set of tax rules (that will close unintentional loopholes that previously allowed organizations to benefit from double non taxation) through an international comprehensive and coordinated approach.

The BEPS project will possibly impact both the domestic law of each state and the provisions of the double tax treaties.

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In such a constantly evolving tax environment, it is crucial for businesses not only to fully understand the current tax debate, but also to consider and anticipate any potential impact on existing structures or on future transactions.

What are the key questions to which multinational enterprises should seek answers?

  • What are the BEPS-driven developments in individual countries?
  • How may those developments affect my business?
  • Are our transactions and structures currently in place or in progress BEPS-compliant?
  • Is the substance of my company still appropriate?
  • What is the best possible tax strategy for my company in the future?
  • Am I prepared to communicate publicly about these strategies?

In order to help you answer these questions and address this challenge in the most timely and efficient way, KPMG has put together a dedicated BEPS team (both in Luxembourg and at KPMG Global level).

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