Comments on Action 7 of the OECD’s base erosion and profit shifting (BEPS) project show the draft has done little to clarify permanent establishment (PE) issues with many countries considering national measures to tackle profit shifting
The Davis Tax Committee recently published recommendations for the OECD and the South African Revenue Service (SARS) regarding base erosion and profit shifting (BEPS). The committee’s comments highlight the lack of concrete and compulsory TP requirements in South Africa.
The Ukrainian Parliament has passed new transfer pricing provisions which will flesh out documentation requirements and extend audit periods. The legislation highlights the government’s desire to tighten transfer pricing control.
The UK government’s plans to introduce a Diverted Profits Tax (DPT), before the completion of the OECD’s work on base erosion and profit shifting (BEPS), could create uncertainty within the UK’s tax system despite being consistent with international efforts to tackle aggressive tax planning.
The Chinese State Administration of Taxation (SAT) has announced that general anti-avoidance rule (GAAR) measures will take effect from February 1 2015. The move signals a crackdown on profit shifting, which could see cross-border transactions increasingly scrutinised.
