On October 5, 2015, the OECD Secretariat published 13 final reports detailing actions under the base erosion and profit shifting (BEPS) project. 62 countries participated in the BEPS project and they will continue to work together until 2020.
For the next two years, the countries will chiefly focus on keeping an eye on the implementation of the action items as opposed to developing new policies. The first action to be implemented relates to transfer pricing. The OECD model tax treaty applies arms-length pricing with the goal that “transfer pricing rules secure outcomes that see operational profits allocated to the economic activities which generate them.”
The next action item to take effect is country-by-country reporting, which requires that member countries report their business activities on a country-by-country basis. The first set of country-by-country data is due to tax authorities by December 31, 2017.
The final action to be implemented within an early timeframe relates to intellectual property or patent boxes. Under this approach, patent box incentives may only be granted where R&D activity is conducted in the country.
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