BEPS Actions Part II

Abstract

This chapter looks at BEPS Actions 8–15 which encompass work in the areas of; transfer pricing (of intangibles, risk, and other high risk transactions), BEPS data collection and analysis, disclosure of aggressive tax planning arrangements, transfer pricing documentation requirements, country-by-country (CbC) reporting, dispute resolution methodologies and, the development of the Multilateral Instrument (MLI) The latter part of the BEPS Action Plan focuses more on oversight and reporting requirements, while the multilateral instrument provides a mechanism for widespread and simultaneous modification of bilateral tax treaties. This chapter provides discussion surrounding the key points of the Action Plan and looks at how businesses may be impacted.