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Transfer pricing newsletter - July 2014

What measures have been taken by the different countries following OECD’s Action plan to fight against Base Erosion and Profit Shifting?

In July 2013, the finance ministers of the G20 countries met in Moscow. They have reiterated their will to fight against aggressive tax planning that may raise budgetary issues for the countries. During this meeting, the OECD presented its Action plan to fight against Base Erosion and Profit Shifting (BEPS hereafter). 15 actions structure this plan and should be translated into concrete measures by December 2015.

BEPS addresses transfer pricing issues as they are often considered by administrations as a tool for tax optimisation. Thus, actions 8, 9, 10 and 13 explicitly deal with transfer pricing. Yet, BEPS is not limited to this matter.

About a year after the publication of BEPS, many countries have already adopted new rules that are in line with the Action plan.

CMS transfer pricing team 

Focus  

BEPS France 
Fighting against tax evasion has been a major concern in France for the Tax Administration, the Parliament and the Government over the last several years. Alongside OECD’s work, the Senate, the Inspection Générale des Finances (the audit department of French public services) and the National Assembly have published reports in this respect. 
To know more

BEPS Germany 
Germany supports all 15 measures of the action plan on base erosion and profit shifting (BEPS) of the OECD. Main parts are already covered by German tax law. Further actions are supported by Germany  
To know more

BEPS Italy 
BEPS has not yet been implemented in Italy. And perhaps it cannot be implemented since the Italian legislation and the relevant Supreme Court interpretations already provide a significant number of remedies against base erosion and profit shifting 
To know more 

BEPS Russia 
Provided that Russia is not a member of OECD, the BEPS initiatives are not subject to compulsory implementation in Russia. However, Russia has repeatedly expressed its consent and approval of deoffshorization initiatives which are consistent with the terms of BEPS.  
To know more    

Hot topics
  • Germany   
    Retroactive Transfer Pricing Adjustments in Germany: Restrictions and Possibilities 
    To know more 
  • Italy   
    Hot topics on transfer pricing as regards to the latest case law  
    To know more
  • Slovenia   
    On the road to APA?  
    To know more

Publications

Read Transfer Pricing Newsletter on "BEPS"

Authors

Xavier Daluzeau
Xavier Daluzeau
Partner
Paris
Bailly Benoît
Benoit Bailly
Partner
Paris
Picture of Valentin Lescroart
Valentin Lescroart
Counsel
Paris
Tissot Dominique
Dominique Tissot
Partner
Moscow
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