BEPS 15 Point Plan

September 23, 2014

Last week the OECD published an action list for the first 7 points of its 15 point plan on BEPS (base erosion and profit shifting).  The purpose behind the BEPS project is for OECD Member States to agree a plan to ensure the business profits of companies are aligned to where the business activity takes place and to curtail international anti-avoidance tax planning.  The OECD conclusions will be key for Ireland’s corporation tax policy.  The question arises for Ireland as to whether it should take unilateral action now or wait until the OECD reach agreement and we are likely to know the Minister’s view in the forthcoming Budget.  The perceived wisdom initially was that we should take no unilateral action but weekend newspaper reports (and IBEC) suggest we should make some changes to our corporation tax rules in the October Budget.  Interestingly, the US Treasury last night announced changes to their corporation tax rules for companies transferring tax residence outside the US by using a so called “inversion” process.  The UK have said they are committed to introducing country by country reporting rules for multinationals which is one of the recommendations on the action list.