The OECD’s final BEPS recommendations

With the release on Monday of the overwhelming bulk of the OECD’s final BEPS proposals we are now close to the end of the policy development stage of what has always been an enormously ambitious project to reform the international tax rules. In fact the BEPS project arguably represents the most significant attempt to reform the existing international tax rules in recent decades. It has the potential to affect and fundamentally change the manner in which MNCs are taxed and the way in which taxing rights are allocated between states not to mention its obvious impact on highly structured cross border tax arrangements which are perceived as lacking real substance.

In the discussion that follows we aim to comment on the key changes that are being made by the finalised BEPS papers highlighting in particular further changes that have...