BEPS: Collection of KPMG Insights

December 21, 2021 | BEPS 2.0 in LATAM: Implications and Complications

KPMG Destination Country X podcast - Anticipated BEPS 2.0 changes will affect all adopting Inclusive Framework members, but do we actually understand how? In this podcast, the potential implications of Pillars One and Two in a number of countries in Latin America—Costa Rica, Mexico, Panama, and Uruguay—are discussed.

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December 2021 | PMG EU Tax Center Report: CBCR Overview

This publication offers an overview of country-by-country reporting (CBCR) from a European Union (EU) perspective.

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November 12, 2021 | Tax 2.0: Pillars to Post on BEPS and U.S. Tax Reform

KPMG Destination Country X podcast - It’s taken a bit—time, effort, and diplomatic magic—but with almost all of the Inclusive Framework on board, Pillars 1 and 2 are on the near horizon. Listen to this podcast to learn where things stand on the global stage? which jurisdictions stand to win big and which ones not so much? and how, as a practical matter, is this going to work out in the United States?

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November 5, 2021 | Managing Multinational Controversy | Tax Management International Journal

Multilateral controversies will likely increase in coming years, as a result of BEPS 2.0 as well as changes in how business and tax authorities operate. In this article, the authors describe approaches to addressing tax controversies with multilateral dimensions.

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October 20, 2021 | Between Two Pillars, Part 3: Mind the Gap

KPMG Inside International Tax podcast - In April and July episodes, we explored the OECD two-pillar approach to the challenges of taxation of the digital economy, including a historic July 1 Inclusive Framework (IF) agreement. In this episode, we unpack the most recent IF statement, which fills in details left open in July but leaves unanswered important issues, and to explore remaining political and practical obstacles to implementation.

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October 9, 2021 | KPMG Report: OECD/G20 Inclusive Framework Agreement on BEPS 2.0

This report provides initial analysis by KPMG professionals of the BEPS 2.0 statement approved by the OECD/G20 Inclusive Framework on October 8.

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July 26, 2021 | Between Two Pillars, Part Deux: Consensus or Contentious?

KPMG Inside International Tax podcast - In April, we explored the OECD’s two-pillar approach to the challenges of the digital economy and the global movement to coordinate taxation of multinational enterprises. This podcast discusses the recent agreement by the G20 and the OECD Inclusive Framework on the two pillars and examines the many obstacles, political and technical, that the OECD must overcome to turn this agreement into reality.

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July 2, 2021 | KPMG Report: OECD/G20 Inclusive Framework Agreement on BEPS 2.0

This report outlines initial impressions and observations from KPMG professionals about the Inclusive Framework statement approved on July 1.

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July 2021 | Finding Consensus: BEPS 2.0 and Tax Certainty | International Tax Review

In this article, the authors examine the Inclusive Framework’s July statement on pillars one and two and consider what it has to say about dispute prevention and resolution.

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June 7, 2021 | KPMG Report: Analysis and Observations about Tax Measures in G7 Communique

June 5 G7 Communique signals political consensus among G7 (United States, Canada, France, Germany, Italy, Japan, United Kingdom, and European Union) on several key issues related to the ongoing negotiations around OECD efforts to address tax challenges from globalization and digitalization of the economy.

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June 2021 | KPMG EU Tax Centre Report: Overview CBCR Initiatives

This publication sets out a high-level summary of the various initiatives (adopted and pending) calling for country-by-country reporting (CBCR) to tax authorities and/or the public.

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May 24, 2021 | The Misalignment of CbC Reporting and Value in Modern Business | Tax Notes International

In this article, the authors examine country-by-country reporting, highlighting potential audit risks, misuses, and misunderstandings associated with it, and they offer some suggestions on ways taxpayers can address and potentially mitigate audit risk and related tax exposure stemming from their CbC reporting positions.

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April 28, 2021 | Between Two Pillars: The U.S. at the OECD

KPMG Inside International Tax podcast - There’s plenty of activity on the domestic front in terms of international tax reform. And, it’s all taking place in the context of a wider global movement to coordinate the taxation of multinational enterprises. This podcast explores the latest OECD action on Pillars One and Two and considers how aspects of these proposals relate to current proposals in the White House “Made in America Tax Plan.”

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April 12, 2021 | MAP: Past, Present, and Future | Tax Notes International

In this article, the authors examine how the OECD's base erosion and profit-shifting project has changed the way governments handle mutual agreement procedure cases under tax treaties.

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March 29, 2021 | OECD Hybrid Rules vs. U.S. DCL Rules: Achieving Tax Harmony | Tax Notes International

In this article, the author examines how U.S. rules on dual consolidated losses interact with OECD recommendations, arguing that without careful international coordination, the U.S. rules could create stranded losses in the relevant jurisdictions.

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January 11, 2021 | Off the MAP: Dispute Resolution in the BEPS 2.0 Blueprints | Tax Notes Federal

In this article, the authors examine the dispute prevention and resolution mechanisms discussed in the OECD’s pillar 1 blueprint for taxing the digital economy.

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January 6, 2021 | Digital Services Tax: Why the World Is Watching | Bloomberg Tax

In response to digital services taxes (DSTs) that have been proposed by the European Commission and a number of countries, the United States has threatened to impose retaliatory tariffs, arguing that DSTs unfairly target U.S. multinational corporations. This article summarizes the various DST proposals globally and discusses potential duty mitigation strategies should the United States choose to respond with retaliatory tariffs.

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