Companies Unlikely to Meet OECD BEPS Tax Deadline

One-quarter of corporate tax and transfer pricing directors believe their companies will fail to meet the first deadline proposed by the Organization for Economic Cooperation and Development in its Base Erosion and Profit Shifting Action Plan, according to a new survey.

Finance ministers for the G20 countries called on the OECD to develop the BEPS Action Plan to help nations align their corporate tax policies. This week, the OECD is presenting the plan to G20 finance ministers meeting in Lima, Peru (see OECD Proposal Could Curb Tax Loopholes Favored by Google, Apple).

The impact of the plan is already reverberating in several countries—including the U.K., Australia, Spain, Mexico, the Netherlands, Poland, South Korea, Singapore and China—which have proposed new corporate tax and transfer pricing rules broadly reflecting the tenets of the BEPS Action Plan even before it is officially delivered.

The Thomson Reuters survey found that European companies are more intensely focused on BEPS planning than their peers around the world. The majority of respondents (59 percent) from European-based companies said they are proactively preparing for BEPS, compared with 48 percent of companies in the Americas and Asia Pacific.

In addition, 47 percent of European respondents said they spend between 2 to 15 hours per week on BEPS activity, compared with 26 percent for the Americas and Asia Pacific.

This regional disparity may be due to the higher degree of BEPS-related activity taking place in Europe compared with the U.S., where there has been little legislative discussion of the OECD’s recommendations.

Europe also leads the world in BEPS activism. Among all respondents, 19 percent said their companies have submitted comments to the OECD regarding the BEPS discussion drafts, but in Europe it was 45 percent.

This regional disparity also is seen in internal company discussions about the BEPS Action Plan. Overall, 55 percent of survey respondents said they have addressed the issue with their boards of directors—although the number drops to 39 percent in the U.S. and rises to 63 percent in Europe.

“While many multinationals corporations are diligently preparing for BEPS, some are constrained by limited resources, and others are adopting a potentially dangerous wait-and-see approach,” said Brian Peccarelli, president of the Tax & Accounting business of Thomson Reuters, in a statement. “With the first deadline just over 24 months away, MNCs need to be resolute in their strategy if they are going be fully compliant by 2017.”

Most respondents said transfer pricing requirements, specifically documentation and country-by-country reporting, are their greatest concern among all BEPS actions. Globally, 74 percent said they will complete their country-by-country analysis by the first due date, Dec. 31, 2017.

In addition, two-thirds of respondents reported their IT systems do not integrate with their transfer pricing policies, an issue that could leave them exposed and will need to be addressed in the post-BEPS landscape. Furthermore, half of respondents said their companies do not have a central database of important intercompany agreements and tax rulings required to comply with the new transfer pricing documentation requirements.

For more information, visit https://tax.thomsonreuters.com/BEPS-Survey.

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Tax practice Tax research
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