BEPS 1.0: The Base Erosion and Profit Shifting (BEPS) initiative, a G20-led effort to prevent tax avoidance through profit shifting, has been in effect from 2012 to 2015. Launched by the G20, BEPS 1.0 included 15 actions—steps that individual countries were encouraged to take to prevent tax avoidance through profit shifting. BEPS 1.0 resulted in profit allocations being increasingly aligned with value creation, with more earnings taxed in countries with more decision-making substance.
BEPS Actions Plans: The OECD has 15 BEPS action plans, which offer guidance for tax challenges arising from digitalization to the prevention of treaty abuse. However, several are devoted solely to transfer pricing. We’ve expanded our analysis of those plans to address their implications for transfer pricing.