Base Erosion and Profit Shifting (BEPS)

Internationally operating companies therefore need high-end strategies to create an effective tax structure. Such strategies need to consider all regulatory developments and acknowledge the change in the international tax climate. Our expert BEPS team can help you to design an international tax strategy and implement optimal solutions.

New regulations are deployed at a rapid pace. This means that you need a team that is on top of the latest developments. Our multidisciplinary team of experts monitors the following developments closely:

• Fundamental changes to transfer pricing rules;
• Limitation of base erosion via interest deductions and other financial payments;
• The EU’s Anti-Tax Avoidance Package / Directive (ATAD);
• Transparency measures (country-by-country reporting, exchange of tax rulings between EU Member States, mandatory disclosure rules, the introduction of the UBO register, etc.);
• Changes to double tax treaties and the multilateral instrument (MLI);
• State aid issues;
• Proposals for the taxation in the Digital Economy
• Proposals for an EU Common Corporate Tax Base (CCTB) and an EU Common Consolidated Corporate Tax Base (CCCTB).

Our advice will always weigh the impact of public opinion on your reputation, while tackling the major tax hurdles. Our BEPS team cooperates with our competition lawyers, state aid/EU tax law experts, litigators and transfer pricing experts, in order to provide you with the best integrated solution for your company.

We advise on and review the impact for multinationals of: 

• The various BEPS measures;
• Fundamental changes to transfer pricing rules;
• Limitation of base erosion via interest deductions and other financial payments;
• The EU’s Anti-Tax Avoidance Package / Directive (ATAD);
• Transparency measures (country-by-country reporting, exchange of tax rulings between EU Member States, mandatory disclosure rules, the introduction of the UBO register, etc);
• The General Anti-Avoidance Rule (GAAR);
• Changes to the double tax treaties;
• The multilateral instrument (MLI);
• Holding structures;
• Group financing;
• IP structures;
• Hybrid mismatches.
• Proposals for the taxation in the Digital Economy
• Proposals for an EU Common Corporate Tax Base (CCTB) and for an EU Common (Consolidated) Corporate Tax Base (C(C)CTB)