BEPS

Base Erosion and Profit Shifting – A project of the OECD to curb international income tax planning.

BEPS, OECD, Permanent Establishments, Tax Avoidance

(Temple Tax Chambers; King’s College London)/ /Leave a comment

The OECD Joint Working Group on Business Restructurings is, in many respects, the precursor to the OECD BEPS project. Unresolved Business Restructuring issues, particularly in relation to permanent establishments, have appeared on the BEPS agenda. One question asked by the Joint Working Group was: Can an agency PE exist if the arrangements entered into did…

BEPS, CCCTB, EU/EEA

(Transfer Pricing Specialist)/ /1 Comment

The German, French and Italian finance ministers, in a letter to the Commissioner for Taxation and Customs, Pierre Moscovici, as of November 2014 (Financial Times, December 1, 2014), have urged the European Commission to curb aggressive tax planning, base erosion and profit shifting (BEPS) in the EU, mainly caused by the lack of tax harmonization…