KPMG Taiwan has published this special edition to better prepare our readers for the anti-tax avoidance movement both domestically and internationally.
Multinational companies through global supply chain distributions, and high net-worth individuals through global wealth configurations, have been able to obtain tax benefits by exploiting gaps and mismatches in tax rules, information asymmetry, investment holding structures inconsistent with economic substance, identity conversion or various contracts and other legal forms of trading arrangements. In recent years, there has been a growing trend of tax measure to prevent the exploitation of Base Erosion and Profit Shifting (BEPS). A global campaign led by the Organization for Economic Cooperation and Development (OECD) has resulted in the BEPS 15 action plans. The BEPS 15 action plans have already encouraged many nations towards tax reforms, as well as amendments to their respective domestic tax laws, including but not limited to the signing of bilateral and multilateral agreements and/or working together as part of a larger international community towards the same end goal of economic substance and tax transparency.
To provide readers with a clear and comprehensive understanding of BEPS and how its associated with Controlled Foreign Company (CFC), the actual management of Place of Effective Management (PEM), tax optimization of Value Chain Management (VCM), the PRC’s Announcement 42 on a three-tiered transfer pricing documentation framework and automatic exchange of financial information on Common Reporting Standards (CRS) related to anti-tax avoidance issues, KPMG Taiwan has published this special edition to better prepare our readers for the anti-tax avoidance movement both domestically and internationally.r
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