John is a partner in kpmg hong kong transfer pricing team. Developing countries reactions to the g20 oecd action. Although this has been the case for a significant period of time, recent changes in the region such as decreases in global oil prices. Bep chemotherapy, for testicular, ovarian and other cancers. What beps means for international business the oecds beps project is set to reshape the international tax landscape kpmgs jane mccormick explains how post navigation. Kpmg example revenue to now include sale of materials, inventories and properties, sale of services, royalty income, interest income, extraordinary income, gain from investment activities and other items. The development of the digital economy, which enables companies to avoid tax through aggressive tax planning, is among the main hardships to which the international tax regime currently has to. Oecd moves toward consensus on taxing multinational tech companies. Kpmg llp, the worldwide audit, tax and advisory firm and one of the big four accounting firms in the us today, is also part of the kpmg international cooperative kpmg international. Beps action latest country implementation kpmg global.
Conrad turley is a tax director with kpmg china and heads up the firms. Base erosion and profit shifting beps is a worldwide project to modernize the international tax system. Mena transfer pricing in a post beps world newsweek. Member firms of the kpmg network of independent firms are affiliated with kpmg. Kpmg recruits beps specialist, michael plowgian, from oecd. Action 15 a multilateral instrument it may take some while for the impact of these recommendations to be fully applied in practice, but the beps project and related developments are constantly leading to the need for business to take action in some cases, urgent action both to comply with new requirements and to consider. In 20, the oecd issued a 15point beps action plan designed to curb its effects. By istina delivan historically, the middle east and north africa mena region has been perceived as a region where taxation and transfer pricing initiatives are not high up on government agendas. It notes that because the digital economy is increasingly becoming the economy itself, it would not be feasible to ringfence the digital economy from the. A read is counted each time someone views a publication summary such as the title, abstract, and list of authors, clicks on a figure, or views or downloads the fulltext. The new research looks at the existing data sources.
The oecd action plan on beps, introduced in 20, set 15 specific action points to ensure international tax rules are fit for an increasingly. The chinese tax authorities have long been known for their. Overview of the oecdg20 beps project linkedin slideshare. Croatia cbc notification filing guidance and penalty information updated information in kpmgs action summary report. Apr 15, 2016 kpmg explains how beps is transforming international business the beps project has done a great deal to shine a light on the risks associated with tax loopholes. In brief, to the extent that the beps recommendations produce a fairer tax system, they are best implemented on a consensus basis with a clear view of their effects. Thailand has agreed to participate in the oecds beps inclusive framework. International trade international tax kpmg enterprise. Acc hong kong base erosion and profit shifting beps. Final report of beps were published what is the next. Apr 15, 2016 the global tax climate is changing under pressure from economic and social trends.
Countrybycountry reporting update and overview of final. Member firms of the kpmg network of independent firms are affiliated with kpmg international. An ebook reader can be a software application for use on a computer such as microsofts free reader application, or a booksized computer that is used solely as a reading device such as nuvomedias rocket ebook. Kpmgs most popular book is tax planning for you and your family.
Books by kpmg goodreads meet your next favorite book. Taxnewsflashbeps kpmgs reports about oecds base erosion. Status of beps action local implementation, transfer. The oecds beps project is set to reshape the international tax landscape kpmgs jane mccormick explains how. Areas of discussion tax morality and transparency1 3 oecd beps action plan3 9 action 1 addressing the tax challenges of the digital economy4 15 action 2 neutralizing effects of hybrid mismatch arrangements5 21 action 6 preventing the granting of treaty benefits in. Plowgian will help support the firms international tax practice in assisting corporate multinational clients in navigating the everchanging business and international tax landscapes. The oecd guidelines provide five transfer pricing methods that are accepted by nearly all tax authorities.
South africa signs the multilateral beps convention tax. Michael plowgian, a senior advisor at the oecd has joined kpmg as a principal in the firms washington national tax practice. Multinationals are concerned with how they will be affected and how tax authorities will be applying beps regulations. The oecd began work on their beps project to address concerns that current principles of national and international taxation were failing to keep pace with the global nature of modern trading and business models, in particular, a perception that existing rules give businesses too much opportunity for arbitraging tax rates and regimes. Areas of discussion tax morality and transparency1 3 oecd beps action plan3 9 action 1 addressing the tax challenges of the digital economy4 15 action 2 neutralizing effects of hybrid mismatch arrangements5 21 action 6 preventing the granting of treaty. Having lived and worked in asia for over 15 years, john has extensive experience in transfer pricing issues across the asiapacific region with respect to japan, korea, hong kong, singapore, taiwan, china, india, indonesia, philippines, vietnam, thailand and australia. The report recommends domestic law changes to neutralise the effect of certain payments or deemed payments involving branches. The five transfer pricing methods with examples conclusion. Global fs view on beps latest developments for financial services. Nov 28, 2017 the launch of the oecds inclusive framework on base erosion and profit shifting beps shows that tax authorities have become more committed to rooting out perceived tax avoidance and maximising revenues. Susan earned her mba at the university of chicago booth school of business and her ba from scripps college. The amendments address beps issues that arise out of or were emphasized by the oecdg20 beps plan.
To fix the global tax system, solutions beyond beps are needed. So with the oecds base erosion and profit shifting project. As per the beps project, jointly initiated by oecd and g20 countries, fifteen action plans were released on 5th october, 2015. The results are nothing short of transformational, according to jane mccormick, global head of tax, kpmg. Base erosion and profit shifting beps refers to corporate tax planning strategies used by. Beps, as it is known, is an effect of transfer pricing in which national tax rules are exploited to enable companies to shelter in taxadvanta geous locations so little or no corpo rate tax is paid.
Here are some of the latest articles from our content contributors. Kpmg sustainability report 2016 37 contact details and addresses sao paulo rua arquiteto olavo redig campos, 105 6th to 12 th floor ez towers 04711904 sao paulo, sp. Beps practices cost countries 100240 billion usd in lost revenue annually, which is the equivalent to 410% of the global corporate income tax revenue. G20oecd beps project advances tax certainty agenda with the. Kpmg explains how beps is transforming international business. In a nutshell the guidelines contained within the discussion draft document are intended to replace the existing oecd guidelines on tp. Member firms of the kpmg network of independent firms are affiliated. Kpmg explains how beps is transforming international business the beps project has done a great deal to shine a light on the risks associated with tax loopholes.
There is now renewed momentum to achieve a solution by the end of 2020. These include 3 traditional transaction methods and 2 transactional profit methods. Oct 21, 2015 7 hybrid mismatch preferential regime maximise deductions beps in a nutshell 7 parent co intermediate co 2 intermediate co 1 ultimate residence country high tax low tax intermediate country high tax intermediate country market or production country high tax local activity avoid taxable presence or minimise assetsrisks. Oecd unveils beps plan to curb tax evasion by mncs oecd unveiled final plan for a comprehensive and coordinated reform of international tax rules, called beps, which will be. Book value of tangible assets on the entitys yearend balance sheet. Thomson reuters is the worlds leading source of intelligent information for businesses and professionals in tax and accounting. The five transfer pricing methods explained with examples. A coordinated action plan from the oecd against base erosion and profit shifting. Data and economic analyses countries have worked collectively to provide a range of reasonable estimates of the magnitude of beps and its economic impact.
Tax avoidance revisited in the eu beps context book ibfd. We welcome new contributors to help make this conversation as robust as possible. Base erosion and profit shifting beps kpmg luxembourg. Best efficiency point, the point on a pump curve that yields the most efficient operation. Belgium cbc notification submission information updated language in kpmgs action summary report. Beps action plans 810 and the oil and gas industry pwc. Patching up a broken tax system why beps is not the solution. Business today caught up with jane mccormick, global head of tax at kpmg in the uk, and discussed how beps is shaping the global tax regime, the challenges of.
Mar 08, 2017 business today caught up with jane mccormick, global head of tax at kpmg in the uk, and discussed how beps is shaping the global tax regime, the challenges of taxing a digital economy and the. Tax challenges of the digital economy action 1 the spread of the digital economy poses challenges for international taxation. The organization for economic cooperation and development is making progress on dealing with the tax challenges of the digital economy. Working together in the oecdg20 inclusive framework on beps, over 5 countries are implementing 15 actions to tackle tax avoidance, improve the coherence of international tax rules and ensure. Kpmg internationals member firms have 145,000 professionals including more than 8,000 partners, in 152 countries. This means that wasteful tax breaks and harmful tax giveaways will continue to undermine tax revenues globally. It will likely have an impact on the majority of multinational enterprises. The document suggests a more holistic approach to the matter, and states that the obtaining of. Mena transfer pricing in a post beps world newsweek middle east. This report sets out an analysis of these tax challenges. Oecd report on action 1 generally reemphasizes that vat should be imposed in the jurisdiction. Roxanna nyiri, head of international tax and transfer pricing. Countrybycountry reporting update and overview of final and temp. The global tax climate is changing under pressure from economic and social trends.
Transfer pricing methods are quite similar all around the world. Over countries are working toward reaching a consensus on reforms to the global tax system in order to deal adequately with the digitalised economy. So with the oecds base erosion and profit shifting project set to reshape the international tax landscape, what. Beps in a nutshell domestic laws not coordinated global develop ments lack of relevant information to combat beps harmful tax practices beps action plan 20 international tax standards have not kept pace with changing global business developments application of harmful tax practices in some places action plan published on 19 july 20 by the. The oecds base erosion and profit shifting beps has been at the forefront of international tax discussions over the last number of years.
Books and accounts shall be prepared and certified by thai qualified registered. Benign enlargement of the prostate, or benign prostatic hyperplasia, noncancerous increase in size of the prostate. In 2017, we saw china continue with its rollout of the beps changes, make. Beps does not end the race to the bottom as countries undercut each other on tax rates. Beps predominantly impacts headquartered entities in a particular country, as the tax administrator of such country would like to ensure that profits attributable to valuable intangibles and strategic functions, which are generally owned and performed by headquartered. Although this has been the case for a significant period of time, recent changes in. Status of beps action local implementation, transfer pricing several countries recently indicated that they envisage implementing or have implemented ycbc reporting and other tp disclosure requirements based on action of the beps action plan. We stated in our main submission on the bill that we do support the need to recalibrate the international tax system. There are two main areas where the rules could strike trouble, explains wardelljohnson.
Our international panel shared their latest market insights as to what beps means for. The contents of the books is given below sn description page no. The oecd measures may result in double taxation in the short term while the lines are redrawn and thought through, says grant wardelljohnson, global spokesman on beps at kpmg. Theyre investing in data scientists and other resources, while subjecting taxpayers to a new level of scrutiny. The global responsible tax project seeks to create the space across the world to have such a debate. Oecd unveils beps plan to curb tax evasion by mncs the. Oecd final report on branch mismatch structures 25 august 2017 in brief the oecd, on 27 july 2017, released its report, neutralising the effects of branch mismatch arrangements action 2. Nontaxable income under a tax treaty cannot be reduced from book.
Base erosion and profit shifting kpmg united kingdom. Asia pacific tax weekly newsletter kpmg international. The work shows that beps is significant and serious source of a concern in terms of lost government revenues. The oecd publishes its latest proposals in relation to its beps 15 point action plan. Kpmg international cooperative kpmg international is a swiss entity.