OECD’s Action Plan published on Base Erosion and Profit Shifting (BEPS)


The publication of the Action Plan and the items listed therein represent a milestone in the ongoing debate on how policy makers and governments will deal with base erosion and profit shifting in the near to long-term future. The desired outcome of the OECD’s BEPS Project is to provide balanced and effective strategies for countries concerned with base erosion and profit shifting, by focussing on e.g. the treatment of hybrid instruments and aggressive debt structuring/interest deductibility.

Companies have an interest to take a closer look at how the action plan focusses on changes that are likely to be introduced over the next two years in domestic rules, OECD Model Treaty provisions and Commentaries and Transfer Pricing Guidelines.

We have thoroughly reviewed the document and summarised the main notions and observations in the attached Tax Policy Bulletin. Please contact your regular PwC team or Isabel Verlinden (ext 4422) or Axel Smits (ext 3120) for more informattion.


Webcast replay

Were you unable to attend PwC’s webcast on Tuesday, July 23, 2013?

The webcast archive is available for 90 days. For your reference, you may download a copy of the presentation and access the archived replay of the webcast by register here: click here

Following the OECD’s February 2013 Report on Base Erosion and Profit Shifting (BEPS), the Coordinated Action Plan was released on 19 July in advance of the G-20 Finance Ministers Summit. The OECD’s aim is to provide comprehensive, balanced and effective strategies for countries concerned with base erosion and profit shifting.

Join specialists from PwC’s global Transfer Pricing Network to better understand the BEPS Coordinated Action Plan release and the potential impact on the existing Treaty and Transfer Pricing Guidelines framework and on Taxing Authorities.

This one hour webcast will cover:

  • Summary of the BEPS Coordinated Action Plan
  • Transfer Pricing and the Arm’s Length Principle under BEPS
  • Inter-relationship with other OECD projects including Intangibles and the Risk Assessment Handbook
  • Permanent Establishment issues
  • Economic substance and other anti-avoidance issues


  • Tony Clemens – Partner, PwC Australia
  • Richard Collier – Partner, PwC UK
  • David Ernick – Principal, PwC US
  • Adam Katz – Partner, PwC US – Moderator
  • Aamer Rafiq – Partner, PwC UK
  • Isabel Verlinden – Partner, PwC Belgium

Benefits from your participation

  • Gain a better understanding of:
    • the anticipated BEPS Coordinated Action Plan release, and
    • the broader OECD agenda and potential changes in the existing treaty framework, and
    • the impact on the approach taken by taxing authorities.
  • Earn up to one CPE credit

Who should attend?

Companies with a global footprint who are concerned about potential changes to the current international tax standards.

PwC can assist you with optimising the tax impact. For more information, please contact your regular PwC contact or visit our website.