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Multinational enterprises (MNEs) may be concerned about various aspects of the six Discussion Drafts released last week as part of the Base Erosion and Profit Shifting (BEPS) Action Plan.
Three of the papers are within Action items 8 to 10 of the BEPS Action Plan dealing with assuring that transfer pricing outcomes are in line with value creation. One of the other papers is the first step towards producing best practice rules to address base erosion and profit shifting through the use of interest expense within Action item 4 of the Plan. The latest proposed additions to the draft International VAT/GST Guidelines relate to supplies of services and intangibles to consumers, raised in the initial report on the digital economy within Action 1. The final paper is an overarching look at the resolution process involving cross-border tax disputes.
Responding directly to the OECD with specific examples is the most powerful way that businesses can address issues which would arise if proposals were adopted. Businesses may also like to consider attending and speaking at the various public consultation meetings on these papers at the OECD's offices in Paris.
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