In 2013, the OECD launched an ambitious Action Plan on BEPS that identified 15 Actions with a view to foster the coherence of corporate income taxation at the international level and to eliminate perceived tax avoidance.

The abbreviation BEPS stands for “Base Erosion and Profit Shifting” and characterizes tax planning in the broadest sense.

The BEPS Project will have a significant impact on the international tax landscape.

The changes that may be expected in regard to domestic tax laws, tax treaties and other international tax instruments will change the way multinational enterprises structure their business activities and how cross-border investments will be implemented and managed.

ATOZ has designed the BEPS SCAN to help clients assessing whether their investment structure is sustainable in the post-BEPS era and, if necessary, how a set-up can be made more robust from an international tax perspective.

The BEPS Scan focuses on the impact of the 15 BEPS Actions on a given investment structure and provides a snapshot as to whether a set-up is fit for the post-BEPS era.

There is no “one size fits all” approach. Instead, each individual set-up has to be carefully analysed in order to determine whether certain elements of a structure will not be efficient in the post-BEPS-era and require structure alignment.

The highly condensed output of the BEPS Scan should enable members of the board of directors and investors to assess the situation of their company.

Our BEPS Scan focuses, in particular, on the following areas:

  • Substance and corporate governance;
  • Structuring aspects;
  • Transfer pricing documentation. 

We may also assist you with the implementation of correcting measures. Here, ATOZ offers one-stop shop solutions with an integrated approach towards, tax advice and structuring, corporate implementation and transfer pricing documentation.