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The integration of national economies and markets has increased substantially in
recent years, putting a strain on the international tax rules, which were designed more than
a century ago. Weaknesses in the current rules create opportunities for base erosion and
profit shifting (BEPS), requiring bold moves by policy makers to restore confidence in the
system and ensure that profits are taxed where economic activities take place and value is
created.
Following the release of the report Addressing Base Erosion and Profit Shifting in
February 2013, OECD and G20 countries adopted a 15-point Action Plan to address
BEPS in September 2013. The Action Plan identified 15 actions along three key pillars:
introducing coherence in the domestic rules that affect cross-border activities, reinforcing
substance requirements in the existing international standards, and improving transparency
as well as certainty.The BEPS
package of measures represents the first substantial renovation of the international tax rules in almost a century. Once the new measures become applicable, it is expected that profits
will be reported where the economic activities that generate them are carried out and
where value is created. BEPS planning strategies that rely on outdated rules or on poorly
co-ordinated domestic measures will be rendered ineffective.