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Exactly five years ago, the OECD-G20 BEPS final reports were published, and the international tax world changed forever. Today, we @TaxNotes take a look at four elements of that project and where things stand.
First up: Action 1. I had the huge task of recapping efforts to address the tax challenges of the digitalization of the economy, so I focused on the events leading up to pillar 1, and the evolution of the US position in ongoing talks. https://www.taxnotes.com/tax-notes-today-international/digital-economy/beps-5-years-later-action-1-and-quest-tax-digital-activity/2020/10/05/2d0lg">https://www.taxnotes.com/tax-notes...
The concluding chapters of action 1 are still being written--watch this space on October 12 when the OECD publishes its draft blueprints for pillars 1 and 2.
(Special thanks to @rescobarstack and Brian Jenn, who represented the US during the BEPS project& #39;s formulation and in the inclusive framework, for sharing their reflections and insights)
Next, @ryanmfinley gives us the rundown on actions 8-10. The takeaway? The report may have updated the OECD’s guidance from a technical standpoint, but it& #39;s doubtful that it provides the basis for a globally consistent approach to transfer pricing. https://www.taxnotes.com/tax-notes-today-international/transfer-pricing/beps-5-years-later-still-no-convergence-transfer-pricing/2020/10/05/2d0jz">https://www.taxnotes.com/tax-notes...
The transparency aspects of the BEPS project (action 13, country-by-country reporting and action 5, harmful tax practices) along with the common reporting standard, have proven to be game changers in international tax, writes @KiarraStrocko. https://www.taxnotes.com/tax-notes-today-international/base-erosion-and-profit-shifting-beps/beps-5-years-later-tax-transparency-global-norm/2020/10/05/2d0jb">https://www.taxnotes.com/tax-notes...
Last, but not least, Annagabriella Colón takes a closer look at action 15, the multilateral convention, which implements the treaty aspects of the BEPS project. The MLI won& #39;t be used to implement any pillars, but could offer inspiration. https://www.taxnotes.com/tax-notes-today-international/treaties/beps-5-years-later-practitioners-give-mlis-effectiveness-mixed-reviews/2020/10/05/2d0jw">https://www.taxnotes.com/tax-notes...
Now, we& #39;re on to the 2nd phase of the BEPS project, with two pillars that "could represent a milestone in multilateral coordination of international tax rules," writes @InternationlTax. Essential reading ahead of the Oct 12 release of the P1/P2 blueprints: https://www.taxnotes.com/tax-notes-today-international/digital-economy/oecd-pillars-bretton-woods-moment/2020/10/05/2d0jg">https://www.taxnotes.com/tax-notes...
And here& #39;s Rick Minor for @TaxNotes, taking a closer look at what the plan could be for winding down unilateral measures, like digital services taxes, as part of pillar 1. https://www.taxnotes.com/tax-notes-today-international/digital-economy/oecd-draft-blueprint-includes-coordinated-end-dsts/2020/10/05/2d0dn">https://www.taxnotes.com/tax-notes...
A final note to cap off the thread: I understand there will be an OECD Tax Talk scheduled for October 12, focusing on the pillar 1 and pillar 2 blueprints. Mark your calendars! The BEPS project story is not yet finished.
And there it is. See you all next Monday! https://twitter.com/oecdtax/status/1313146499761688579">https://twitter.com/oecdtax/s...
