The Eastern Europe and Central Asia Regional Meeting and Governmental Workshop on base erosion and profit shifting (BEPS) met on 21 to 23 October 2015 to discuss the implementation and monitoring of the BEPS outcomes drawn up by the OECD. On 5 October 2015 the OECD published the final papers on the fifteen action points for measures to combat BEPS and is now moving to the implementation stage. The regional meetings are discussing how all countries can implement the measures on an equal basis. The meeting included officials from fifteen countries in addition to the OECD and other interested bodies from business and the NGO sector.
Views were obtained on the development of toolkits to address issues identified by developing countries as significant, and implementation of BEPS solutions that target the interests of developing countries. Toolkits would need to be based on the experience in each country to make them workable.
Following presentation of the final BEPS package the delegates discussed the challenges and opportunities of BEPS implementation and the development of a framework that would allow equal implementation across all countries. They discussed capacity building initiatives and looked at the timeline for implementation of the measures. Discussions focused on the development of practical toolkits that would assist the implementation of workable solutions.
Separate sessions were held on tax incentives, indirect transfers of assets, comparability issues for transfer pricing and transfer pricing documentation. Participants saw the negotiation of a multilateral instrument for implementation of tax treaty changes as particularly important. Twelve of the countries represented at the meeting are already part of the negotiations for the instrument and the others expressed interest.
The participants emphasized the importance of mineral pricing issues and more general tax risks relating to extractive industries and commodities. They welcomed the BEPS work on transfer pricing and the possibility for developing countries to offer input, especially on the changes related to transfer pricing and commodities.
The delegates pointed to the limited resources of national tax administrations and limited possibilities for training tax auditors. Capacity building initiatives in the region are planned involving the OECD and Tax Inspectors Without Borders programs.
The participants were concerned about the challenges presented in the area of transfer pricing comparability data. The development of a transfer pricing comparability toolkit by the OECD and World Bank in cooperation with other organizations was welcomed. The participants were interested in practical guidance on how the revised transfer pricing guidelines can offer appropriate solutions on the use of foreign data and related adjustments. Questionnaires on comparability data and transfer pricing documentation are to be distributed to countries of the region.