The 2013 BEPS Action Plan recognised that “actions to counter BEPS must be complemented with actions that ensure certainty and predictability for business”. Edward Barret and Evelyn Lio track the work of Action 14 of the BEPS Action Plan, which called for work to improve the effectiveness of the mutual agreement procedure (MAP) and thereby address obstacles that currently prevent countries from solving treaty-related disputes and minimise as much as possible elements of uncertainty related to the interpretation and application of novel rules resulting from the other work on BEPS issues.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The BEPS project has seen the arm’s-length principle shift its focus to where human activity takes place, but Leonard Wagenaar questions if this is sustainable in a financialised world
Anticipating potential changes in tax basis interpretations can help reduce audit risks in tax planning for intercompany equity transfers, says Abe Zhao of FenXun partners