BEPS Action 6 – Challenges for Existing Holding Structures? The OECD’s final report on “BEPS Action 6: Preventing the Granting of Treaty Benefits in Appropriate
BEPS Action 6 – Prevent Treaty Abuse BEPS Action 6 “Preventing the granting of treaty benefits in inappropriate circumstances” recommends that countries include in their
BEPS Action 7 – Artificially Avoiding PE Status BEPS Action 7 “Preventing the artificial avoidance of permanent establishment status” contains agreed amendments to the definition
BEPS Actions 8-10 – Align Transfer Pricing Outcomes with Value Creation BEPS Actions 8-10, “Aligning Transfer Pricing Outcomes with Value Creation” includes new guidance on
BEPS Action 11 – Measuring and Monitoring BEPS BEPS Action 11 “Measuring and monitoring BEPS” aims to establish methodologies to collect and analyse data on
BEPS Action 12 – Disclosure of Aggressive Tax Planning BEPS Action 12 “Mandatory disclosure rules” aims to require taxpayers to disclose their aggressive tax planning
