As the BEPS project proceeds to completion, it is crucial that companies, their tax advisers and tax administrations are aware of the implications of the new international framework grounded on transparency, multilateral cooperation and information exchange, and the new world that awaits us all.
With concepts such as the “spirit of the law”, “economic substance” and “value creation” coming to the fore, tax mitigation and the structuring of companies’ businesses will have to take into account a larger number of variables and a different set of risks: tax and tax governance will definitely have arrived in the boardroom.
In a “post-BEPS” world, transfer pricing disputes as well as spill-over effects of double taxation and the degree of scrutiny of operations in general by tax administrations are expected to increase.
The EU is fully supportive of the BEPS project and is working in parallel on its own programme tackling tax fraud and tax evasion. Close coordination between EU and OECD will be necessary to ensure that the adoption of OECD solutions do not hinder the exercise of the EU´s fundamental freedoms and that the changes put forward by the EU legislators do not damage the competitiveness of EU businesses.
The forthcoming 2015 CFE Forum will address these pressing topics, and will help companies and their tax advisers prepare for the future.
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