The OECD’s Base Erosion and Profits Shifting (BEPS) Action Plan has initiated profound changes to how tax authorities assess transfer pricing. Gradually, governments and tax authorities around the world are introducing a number of recommendations included in the BEPS Action Plan into domestic legislation.
Although efforts have been made to coordinate implementation of the recommendations, uptake has not been universal and as such there are timing differences in when the recommendations will be introduced, if at all. The absence of such coordination presents major challenges to multinational enterprises (MNEs) in relation to both current and future tax liabilities.