BEPS: OECD is gearing up towards the September deadlines


The OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) was published in July 2013 with a view to addressing perceived flaws in international tax rules. The 40-page Action Plan, which was negotiated and drafted with the active participation of the OECD member states, contains 15 separate action points or work streams, some of which are further split into specific actions or outputs. The Plan is squarely focused on addressing these issues in a coordinated, comprehensive manner, and was endorsed by all G20 leaders.

The OECD held its annual tax conference on 2 and 3 June in Washington (DC), focusing almost exclusively on the BEPS project. The general message of the conference was that the BEPS project is on schedule, and that the OECD is preparing to duly deliver on its September 2014 deadline for all action points scheduled.

Seven of the 15 items in the action plan are included in the September 2014 outputs. Three require the delivery of a report or review by the first deadline, although they will be revisited later or drive later actions. Of the other four items, three are likely to involve changes to the OECD’s Model Tax Convention (MTC), two describe changes to the OECD’s transfer pricing (TP) guidelines, and three recommend amending or changing domestic tax rules.