On October 5, 2015 the OECD released the final versions of the 15 BEPS Action Plans. The G20 is due to endorse the Action Plans in November 2015. The BEPS initiative was launched in 2013. The fact that the OECD succeeded in such a short time frame in completing a major overhaul of the rules and concepts generally applied in international tax law is quite impressive. The launch of the final recommendations does not mean that the book on BEPS can now be closed. The BEPS outputs make a distinction between ‘minimum standards', ‘recommendations' and ‘common approaches/best practices'. All OECD and G20 countries have committed to consistent implementation of minimum standards. This concerns especially Actions 6 (Treaty Shopping), 13 (Country by Country Reporting), 5 (Harmful tax practices) and 14 (Improving Dispute Resolution).
The interesting question is whether all countries, both OECD members and non-OECD members alike, will uniformly transpose the OECD's recommendations and best practices/common approaches into local law and/or bilateral treaties, whether some countries will not move at all or whether some countries will introduce rules that substantially deviate from the OECD's recommendations. The question is also how the EU will move forward with its own action plan.
For taxpayers the question is whether the new rules will affect their current position and if so how this position can be adjusted efficiently. Do the new rules increase the risk of double taxation and will they impact the cost of compliance? How will the new ‘normal' affect taxpayers' legal rights? Despite all these questions one thing is clear: today marks the start of a new era in international tax. The pdf provides a brief summary per Action Plan of the major recommendations. Meijburg will also briefly touch upon the question how the recommendations may affect the Netherlands.
Bron: KPMG Meijburg
Informatiesoort: Nieuws
Rubriek: Internationaal belastingrecht
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