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For Corporates, the rethinking its TP becomes an urgent requirement

The pace for OECD’s famous “BEPS” (i.e. Base Erosion Profit Shifting) initiative is accelerating for couple of months. According to a recent Thomson Reuters survey, two third of corporates are already preparing actively to comply. We remain skeptical as lots of corporations (at least for financial operations) seem to focus on other priorities. Last October, the European Commission has announced series of measures e.g. Common Consolidated Corporate Tax Base (CCCTB), Directive on double taxation dispute resolution mechanisms and amendments to the ATAD (i.e. Anti-Tax Avoidance Dir). It has been active and it was followed by member States and other in the world which committed to implement BEPS. Some of the recommendations are already under implementation in some countries. On top of these key measures, do not forget the Multilateral Instrument (i.e. MLI) that changes the way bilateral tax treaties will be updated. We all know how double tax treaties have been in some cases highly criticized. Multinational companies will have to rethink their organization and structures for financing their affiliates. Eventually, we should not forget to mention the so-called “CbCR” standing for Country-by-Country Report, which is rather complicate to set up.

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