11 August 2014 OECD seeks input on collecting and analyzing data on BEPS On August 4, 2014, the Organisation for Economic Co-operation and Development (OECD) published a paper seeking input on Action 11 of the OECD's Action Plan on Base Erosion and Profit Shifting (BEPS) issued on July 19, 2013. The paper, BEPS Action 11: Establish methodologies to collect and analyse data on BEPS and the actions to address it, describes input the OECD requests, including suggestions for possible indicators of the scale and economic impact of BEPS, potential methodologies for estimating the scale and impact of BEPS, available data and methodologies to develop economic analysis of the impact and effectiveness of actions to address BEPS, and new types of data to be collected to monitor the effectiveness of the actions to address BEPS on an ongoing basis. Comments are requested to be submitted by September 19, 2014. Action 11 of the BEPS Action Plan, which has a target date for output of September 2015, involves establishing methodologies to collect and analyze data on BEPS and the actions to address it. The paper notes that the analyses and tasks to be included fall within four categories:
The paper indicates that the OECD has considered some existing empirical studies, including analyses that were described in the OECD's initial report on BEPS issued on February 12, 2013, but that these studies are limited and many cover only a single country or focus only on a particular tax strategy. The OECD also has begun to consider data, indicators, and economic methodologies for monitoring and evaluating actions taken to address BEPS. With respect to the potential need for new data to be collected, the paper notes the need to take into account confidentiality and to minimize administrative and compliance costs for both taxpayers and tax administrations. The paper further notes that for this work, "firm-specific approaches" have advantages over aggregate approaches of "separating BEPS behaviours from real economic activity."
The paper also invites any other comments related to Action 11. Input in response to this paper should be submitted by September 19, 2014 and will be posted on the OECD website (unless otherwise requested). This is the first document the OECD has released with respect to Action 11 of the Action Plan. The OECD's initial report on BEPS, released on February 12, 2013, indicated that existing studies did not conclusively determine how much BEPS actually occurs, but asserted that there was abundant circumstantial evidence suggesting that BEPS behaviors are widespread. Action 11 is aimed at developing such analyses, as well as tools to evaluate and monitor the impact of BEPS counter-measures developed under other elements of the Action Plan. This paper seeks input from interested parties as the OECD begins this work. Of particular note is the OECD's request for any recommendations for new types of data that taxpayers should provide to tax administrators for purposes of future monitoring of BEPS and BEPS counter-measures. This may be an indication of another potential use for the information to be provided in the country-by-country reporting template being developed under Action 13. It may also be an indication that further additional reporting requirements for taxpayers could be recommended by the OECD as part of the BEPS project. Companies should monitor developments with respect to Action 11.
Document ID: 2014-1435 | |||||||
