Of all the BEPS action plans, it is those around transfer pricing that will impact most on a company's tax charge. A rethinking of the fundamentals underpinning arm's length pricing means that the allocation of taxable profits will alter. A focus away from contractual risk and towards value creation activities will bring new complexities in establishing an arm's length remuneration.
Companies will be concerned at how and when the new guidelines will be implemented by individual countries, including Ireland, particularly in the context of IP.
Our recent BEPS seminar looked into this area of BEPS.