The global climate for international tax is rapidly changing. The OECD, the EU and tax authorities around the world have focused attention on tax planning implemented by leading multinational companies. The OECD believes that tax planning and related structures lead to an annual revenue loss of US$100-240 billion. Since 2013, the OECD has been leading a global initiative to attack base erosion and profit shifting (BEPS). This initiative brought together the tax authorities of over 60 countries including all of the G20, the BRICs as well as several major developing countries. Business groups and NGOs participated in an extensive consultation process. The objective of the BEPS initiative is to arm tax authorities with tools to review and attack tax planning that is perceived as aggressive and enable tax authorities to collect what they believe to be their fair share of tax. Unfortunately, the BEPS initiative also impacts commonplace tax planning and will greatly increase the burden of compliance.
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