Sandy Bhogal, head of tax at Mayer Brown in London, outlines where we stand with respect to recent multilateral work to counter base erosion and profit shifting (BEPS) and, specifically, Action 4 of the OECD Action Plan, after first pausing to reflect on how and why we got to this point. Conceptually, Action 4 sought to consider ways to reduce base erosion that can occur through interest payments and other economically equivalent amounts.
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The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals
Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes
Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test
Senior McCarthy Tétrault tax practitioners highlight significant updates and implications for multinationals as Canada’s transfer pricing rules become more closely aligned with OECD guidance