The leaders of the G20 group of countries approved the final package of measures to combat base erosion and profit shifting (BEPS) at their meeting on 15 and 16 November 2015. The BEPS package is based on the fifteen action points addressed by the OECD and includes recommendations for national tax measures, changes to the OECD transfer pricing guidelines and proposed changes to the provisions of double tax treaties. The BEPS recommendations also include the provisions for country by country reporting by parent companies of multinational enterprises.
A number of interested countries are now working together to develop a multilateral instrument to enable them to include the treaty-related BEPS measures into the existing network of bilateral double tax treaties. This instrument is expected to be available for signature by interested parties in early 2016. The treaty-related measures included in the BEPS package can then be implemented as quickly as possible.
