Are You BEPS Ready?

A range of solutions to future proof your TP model


BEPS refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid. 

The OECD’s Action Plan on BEPS was first published in July 2013 with a view to addressing government concerns and international tax reform. The Action Plan, containing 15 separate action points or work streams, was endorsed by G20 leaders and finance ministers at their summit in St. Petersburg in September 2013. The OECD finalised the BEPS report for the G20 on October 5, 2015. 

Many corporates are currently struggling in their response to BEPS and the OECD's proposed template for a country-by-country report (CBCR). 

The Challenge

The global tax environment is rapidly changing. Tax strategies which have been legal and common for many years are increasingly regarded as unacceptable. The public perception that corporates artificially shift earnings to low tax jurisdictions has become a key corporate social responsibility issue. Corporates will increasingly be required to "get naked" in respect of their tax affairs via self-disclosure/reporting and mandatory exchange of information between tax authorities.

Key Strategic Considerations

Your historic approach to disclosure and tax transparency (i.e. how naked you are today).

Your current tax/TP model (i.e. aggressive/non-aggressive) and level of supporting TP documentation, e.g. Masterfile, Local Files.

Adjustments to your TP model or business model in anticipation of BEPS, CBCR, and other international tax developments.

Which source of data to use for CBCR, and whether presentation can be improved by selecting other data sources and/or reporting periods.

The opportunity granted via CBCR Table 3 (i.e. providing more narrative to the tax authorities to aid understanding and proactively address some potential areas of concern).

Questro Solutions

Questro offers a number of BEPS readiness solutions and assessment tools to help you identify your readiness to comply with the new international tax regulatory environment. Such solutions include: 

  • TP/Tax Model BEPS impact reviews and reports across all of the 15 BEPS action points;
  • Stakeholder communication projects covering strategic & operational BEPS implications;
  • CBCR simulation work, to identify any "risky" CBCR positions and take action (i.e. jurisdictions or entities where disclosure of your current fact-pattern may trigger audits);
  • Design and implementation of BEPS TP documentation (Masterfile, Local Files, CBCR); 
  • IT Solution Selection for BEPS.