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BEPS is centre stage

The OECD's base erosion and profit shifting (BEPS) project, commissioned by the G20, has now taken centre stage in global transfer pricing.

With a deadline of September 2014 for initial outputs, following a raft of public consultations, and a final deadline for completion set for September 2015, it's an ambitious project and nothing has yet been decided. But that hasn't stopped taxpayers and their advisers trying to forward plan as to how the final guidelines will impact their businesses and tax structures.

The project has also seen the first serious international discussion about country-by-country reporting, which before the public consultations had begun, was considered a fringe issue and the brainchild of left-wing tax campaigners; rather than something that would ever be accepted by multinational companies.

Tax directors still have a number of concerns about how country-by-country reporting will be adopted by tax authorities around the world, not least because they fear it will provide competitors with sensitive information that will put them at an economic disadvantage.

The OECD needs to iron out the grey areas of country-by-country reporting to ensure that all the information that taxpayers submit to revenue authorities will be crucial and, most importantly, understood and used by revenue officials.

BEPS is, therefore, a big theme in this year's Transfer Pricing supplement with articles looking at what it means for multinational companies, substance and transparency in the context of BEPS and a specific look at how it will impact certain jurisdictions, such as the UK and Germany.

The publication also features an article from Vineet Rachh, a multinational taxpayer, who focusses on the external changes that can impact a company's supply chain and how to manage these issues to promote efficiency in the tax department.

Readers will also benefit from advice about how to choose between the price-setting approach versus the outcome testing approach in Germany, from advisers at PwC; new developments in the Brazilian transfer pricing rules, in an article written by Felsberg Advogados; the Chilean tax reform, by PwC; documentation requirements in France, by LexCase Societe d'Avocats; compliance and reporting outsourcing in Russia, by EY; and US transfer pricing developments from Fenwick & West.

Sophie Ashley

Managing editor

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