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Dbriefs: BEPS Central

Welcome to BEPS Central, your one-stop shop for information on the BEPS Project. Here you can find all the official documents on the BEPS Project, as well as related Deloitte comments.


The database is arranged in 5 parts:

What's new

OECD: 2014 Deliverables
- Neutralising the Effects of Hybrid Mismatch Arrangements (Action 2)
- Preventing the Granting of Treaty Benefits in Inappropriate Circumstances (Action 6)
- Addressing the Tax Challenges of the Digital Economy (Action 1)
- Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance (Action 5)
- Guidance on Transfer Pricing Aspects of Intangibles (Action 8)
- Developing a Multilateral Instrument to Modify Bilateral Tax Treaties (Action 15)
- Guidance on Transfer Pricing Documentation and Country-by-Country Reporting (Action 13)

- Executive Summaries
- Information Brief
- Frequently Asked Questions
- Explanatory Statement
16 September 2014

Dbriefs U.S. Webcast: Base Erosion and Profit Shifting (BEPS) Update: Change Is in the Air
17 September 2014

OECD: BEPS webcast on 2014 Deliverables
16 September 2014



In this section, you will find the documents and comments related to each of the 15 BEPS Actions. Simply click on the relevant action below.

Action 1:
Address the tax challenges of the digital economy
Action 2:
Neutralize the effects of hybrid mismatch arrangements
Action 6:
Prevent treaty abuse
Action 11:
Establish methodologies to collect and analyze data on BEPS and the actions to address it
Action 3:
Strengthen controlled foreign company (CFC) rules
Action 7:
Prevent the artificial avoidance of PE status
Action 12:
Require taxpayers to disclose their aggressive tax planning arrangements
Action 4:
Limit base erosion via interest deductions and other financial payments
Action 8:
Transfer Pricing:
Action 13:
Re-examine transfer pricing documentation
Action 9:
Transfer Pricing:
Risk and capital
Action 5:
Counter harmful tax practices more effectively, taking into account transparency and substance
Action 10:
Transfer Pricing:
Other high-risk transactions
Action 14:
Make dispute resolution mechanisms more effective
Action 15:
Develop a multilateral instrument



BEPS General Information

In this section, we have materials and comments related to the BEPS Project as a whole.

OECD: 2014 Deliverables: Information Brief
16 September 2014

OECD: BEPS webcast on 2014 Deliverables
16 September 2014

Mark Konza (Australian Taxation Office) : "Global tax avoidance and its effects on Australia's economic prosperity" 
26 August 2014


More BEPS general information




Here's a depiction of the deadlines that the OECD has set for itself.

OECD's calendar for planned stakeholders' input 2013-2014.
(continuously updated)

Click on image to enlarge


Source vs. Residence Taxation

In this section, we include documents and comments in regard to Source vs. Residence Taxation, which is a topic not covered by any of the BEPS Actions (but which is a very important "background" issue).

For information on this topic, click here.


Disclaimer note

This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the "Deloitte network") is, by means of this communication, rendering professional advice or services. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.


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