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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Ireland’s Department of Finance reported increased income tax, VAT and corporation tax receipts from 2024; in other news, it’s understood that HSBC has agreed to pay the French treasury to settle a tax investigation
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two