For those who don’t know; BEPS stands for “Base Erosion and Profit Shifting”. As we were saying, the BEPS project also affects small to medium entrepreneurs, so it´s definitely worth dedicating a whole article to help discover how it can affect us and how we can avoid major problems.

the pressures put on low/zero tax jurisdictions to impose substance requirements under Action 5 of the BEPS Action Plan and EU initiatives.

The OECD G20 Base Erosion and Profit Shifting Project (or BEPS Project) is an OECD / G20 project to set up an international framework to combat tax avoidance by multinational enterprises ("MNEs") using base erosion and profit shifting tools. The EU member states have embraced the OECD BEPS recommendations, even though some — such as Cyprus, Croatia, Malta and Romania — are not OECD members. The European Commission has driven the EU legislative agenda for OECD BEPS recommendations. The EU Anti-Tax Avoidance (ATA) Directive specifically includes measures addressing 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 or to erode tax bases through deductible payments such as interest or royalties. Although some of the schemes used are illegal, most are not.

Alternatives to consider: 1. Include a substance analysis (economic reality exemption) 2. Applying CFC rules equally to foreign and domestic CFCs 3. Applying CFC rules to transactions that are ”partly wholly artificial” • Cf. C-524/04 Test Claimants in the Thin Cap Group EU BEPS: Presidency of the Council roadmap on future work On 19 February, the Dutch Presidency of the Council of the EU circulated to EU Member States a Roadmap on EU BEPS, setting out future work in the Council during the coming months in the field of Base Erosion and Profit Shifting (BEPS) at EU level. An EU Anti-Tax Avoidance Directive is proposed to enact three of the BEPS actions consistently across the EU: interest deductions – corporate tax deductions for finance costs will be limited to a maximum of 30 per cent of the taxpayer’s adjusted earnings before interest, tax, depreciation and amortisation (EBITDA) or €1m if higher, subject to an ‘equity escape’ clause modelled on EU law, they must target only the arrangements which are wholly artificial.

EU Commission's outline of Apple's unique hybrid– Double Irish BEPS tax structure in Ireland, that used two branches inside a single company, rather than two separate companies, like most other US multinationals.

The EU's Anti Tax Avoidance Directive follows several of the BEPS Project recommendations, dealing with "hybrid" mismatches between individual country tax treatments of entities and financing instruments, controlled foreign companies, and base erosion through interest expenses. It also imposes a common general anti-avoidance rule (GAAR).

China.

BEPS kommer att innebära ett större uttag av bolagsskatter och en omfördelning av beskattningsunderlaget mellan olika länder. Internationellt sett har BEPS varit det mest omdiskuterade projektet på skatteområdet de senaste åren. Se hela listan på skatteverket.se Se hela listan på skatteverket.se What progress has been made with implementing the OECD BEPS recommendations in the EU? The OECD Base Erosion and Profit Shifting (BEPS) project, agreed in October 2015, provides for 15 Actions to "equip governments with the domestic and international instruments needed to tackle" the erosion of their tax bases and profit shifting for tax avoidance purposes in their jurisdictions. Besides providing a comprehensive technical analysis of the EU Anti-Tax Avoidance Directive (ATAD), this book offers insight on selected issues connected with the OECD Base Erosion and Profit Shifting (BEPS) Project that are important for predicting its possible impact, including on relations with non-EU Member States. On 5 July 2019, the EU (Tax Dispute Resolution Mechanisms) Regulations 2019 (S.I. No. 306/2019) (the Regulations) were published in the Official Gazette of the Government of Ireland. The Regulations implement the EU Tax Dispute Resolution Directive (2017/1852) of 10 October 2017, relating to tax dispute resolution mechanisms in the EU. 29-06-2017.
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profit shifting (BEPS) in the EU context (doc. 15150/15), and on the future of the Code of Conduct (CoC) on business taxation (doc. 15148/15). These conclusions provided the basis for further work by the Council in the area of BEPS in 2016 and endorsed a new Work Package for the Code of Conduct Group. EU-kommissionen presenterade igår, den 28 januari 2016, ett digert paket med flera förslag på nationell lagstiftning och andra åtgärder som på olika sätt avser att motverka multinationella företags skatteplanering inom EU och globalt.

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The EU's Anti Tax Avoidance Directive follows several of the BEPS Project recommendations, dealing with "hybrid" mismatches between individual country tax treatments of entities and financing instruments, controlled foreign companies, and base erosion through interest expenses. It also imposes a common general anti-avoidance rule (GAAR).

Any solution proposed by the EU should consider compatibility with the G20/OECD BEPS 2.0 initiatives. The European Parliament is expected to cast their vote on the draft motion in the plenary session scheduled for April 24, 2021.