Which measures have been included investment decision under risk and uncertainty ppt the BEPS Package? A comprehensive package of measures has been agreed upon. Countries are committed to this comprehensive package and to its consistent implementation.
These measures range from new minimum standards to revision of existing standards, common approaches which will facilitate the convergence of national practices and guidance drawing on best practices. Has the BEPS Project delivered on its promise to put an end to double non-taxation? The expectation is that once implemented, the measures restore taxation in a number of instances where income would otherwise go untaxed. Depending on the planning structure used, one or more of the measures developed will have an impact and ensure that income is taxed at least one time and not more than once. Rather than closing individual schemes, the measures go to their roots. How will the BEPS measures be implemented?
Some of the measures may be immediately applicable such as the revised guidance on transfer pricing. Other measures require changes to bilateral tax treaties, something that can be done via the multilateral instrument under Action 15. Finally, other measures require domestic law implementation. What is the nature of the BEPS outputs? They are soft law legal instruments.
They are not legally binding but there is an expectation that they will be implemented accordingly by countries that are part of the consensus. The past track record in the tax area is rather positive. Do the BEPS measures increase the risk of double taxation? The aim of the measures is to realign taxation with economic substance and value creation, while preventing double taxation.