The Organisation for Economic Co-operation and Development (OECD) has described its newly unveiled Base Erosion and Profit Shifting (BEPS) Action Plan as a ‘change of paradigm’. A few very large global groups aside, a more apt description may be a minefield for the unwary.

BEPS has received considerable air time over the past few years, to the extent that there is a fear that businesses have become detached from the process. But it’s now that they should be critically appraising their current structures to make sure they are fit for purpose in the post BEPS environment. Heads of tax are facing headaches: divergences in domestic legislation, archaic tax authority dispute resolution mechanisms and an eagerness from tax authorities around the globe to ensure they collect their ‘fair share’ of tax. 

In this article we look at:

  • the practical impact of the OECDs recommendations and the key issues that should be on your radar as a tax function and head of tax;
  • how to address these issues and the risks and opportunities they create; and
  • how the tax role within the business is likely to change and the opportunities that this presents.