BEPS in Articles and Publications

Stay informed about ongoing global tax reform—BEPS, tax transparency, and more

Manal Corwin

Manal Corwin

Principal in Charge, Washington National Tax, KPMG US

+1 202-533-3127
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Article series from KPMG

Articles from KPMG on developing BEPS and global tax reform issues and developments ... more to come

CFC Rules under ATAD

Oct. 9, 2019 | Overview and Implementation Status

Tax Departments in the Spotlight

Aug. 8, 2019 | Corporate Tax Transparency

Changing Tax Landscape

July 3, 2019 | BEPS for Asset Management

Current State of Play

June 13, 2019 | BEPS Actions 8–10

2019 to Be a Pivotal Year

May 11, 2019 | Taxation of the Digital Economy

More reports and published articles from KPMG

February 2020

KPMG Report: Insights on OECD's Revised "Unified Approach" to Tax Challenges of Digitalisation

The Organisation for Economic Cooperation and Development (OECD) on January 31, 2020, issued a statement (the Statement) by the OECD/G20 Inclusive Framework on BEPS, reaffirming its commitment to reach a consensus-based long-term solution to the tax challenges arising from the digitalisation of the economy and stating that the Inclusive Framework will continue following a two-pillar approach in working toward an agreement by the end of 2020. The Statement is also accompanied by an updated Programme of Work setting out the timeline for the work on Pillar One and the remaining technical challenges to be addressed. The Inclusive Framework also stated its expectation that any consensus-based solution would need to include a commitment by members to implement the solution and withdraw relevant unilateral measures. This report provides KPMG observations on the Pillar One work.

KPMG Report: OECD Transfer Pricing (Final) Guidance on Financial Transactions: Initial Impressions

As part the base erosion and profit shifting (BEPS) project, Actions 8-10, the Organisation for Economic Cooperation and Development (OECD) on February 11, 2020, issued final recommendations regarding the arm’s-length treatment of various financial transactions among related parties. This follows release of proposed guidance in July 2018 and applies transfer pricing methods to intercompany loans, cash pools, financial guarantees, hedging transactions, and captive insurers. This report provides KPMG initial impressions and observations, including notes about changes from the 2018 draft.

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2019 articles

December

OECD's Unified Proposal on Pillar One Poses Challenges for Dispute Resolution

This column by KPMG professionals outlines some of the issues that the OECD's unified approach raises, particularly in regard to dispute resolution. Appeared in International Tax Review.

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November

Global Glare: International Tax Reform Steals the Spotight

This issue of CTO Insights discusses how CTOs in companies across America are increasingly focused on global tax reform and the OECD's efforts to develop a unified approach to address the challenges presented by the impact and influence of the digital economy.

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October

INSIGHT: Taxing the Digital Economy – As Simple as "A, B, C"?

KPMG professionals examine the OECD Secretariat's October 9 proposal under Pillar One, on the allocation of taxing rights and profits, of the Inclusive Framework. Article appeared in October 21, 2019 issue of Daily Tax Report (Bloomberg Tax).

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September

Digital Taxation: International Focus, Individual Doubt

This issue of KPMG's CTO Insights – Issue Spotlight looks at how chief tax officers are addressing the uncertainty around changing international rules regarding the taxation of the digital economy.

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August

INSIGHT: Cost-Plus Transfer Pricing for Marketing Support Services between BEPS 1.0 and BEPS 2.0

KPMG LLP collected feedback from 26 KPMG International member firms to understand the extent to which a cost-plus transfer pricing remuneration for marketing support services would be challenged in today's environment form a local transfer pricing perspective.

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Archive (2016-2018)

2018

BEAT's Impact on Transfer Pricing Alternative Dispute Resolution, February 16, 2018

Bloomberg Tax | Daily Tax Report

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Across the Line: Navigating Global Tax Challenges, February 2018

KPMG LLP | CTO Insights

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Post-BEPS Tax Controversy—Preparing for New Rules, New Risks, 2018

KPMG LLP

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2017

Understanding the Operation, Impact, and Practical Implications of the MLI, August 11, 2017

Bloomberg BNA | Tax Management International Journal

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Because Not There, Neither Here? Examining the 'Mirror Legislation' Status of the U.K.'s New Anti-Hybrid Rules, August 7, 2017

Tax Analysts | Tax Notes International

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OECD Master File Considerations: North America, 2017

Expert Guides, Transfer Pricing Advisers

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Ten Questions on the OECD's DEMPE Concept and Its Role in Valuing Intangibles, June 1, 2017

Bloomberg BNA | Tax Management Transfer Pricing Report

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Planning for the Future State of Income Tax Treaties: A Primer on the OECD's Multilateral Instrument, May 26, 2017

KPMG LLP | What's New in Tax

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Treaty Benefits for Investment Vehicles in a Post-BEPS World, March 2017

Taxes, The Tax Magazine

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Enhancing Value in a Disruptive Environment, 2017

KPMG LLP

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The BEPS Ripple Effect, Multinationals Are Reevaluating How and Where They Do Business, 2017

KPMG LLP

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2016

Country-by-Country Reporting: Identifying the Elephant, September-October 2016

CCH | International Tax Journal

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Country-by-Country Reporting: Are We There Yet?, July 21, 2016

Bloomberg BNA | Daily Tax Report

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Transfer Pricing for Financial Transactions: Determining Credit Ratings, July 14, 2016

Bloomberg BNA | Tax Management Transfer Pricing Report

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2x4 Approach to Country-by-Country Reporting, May 18, 2016

KPMG LLP

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The Post-BEPS World of Permanent Establishment, May 2, 2016

Tax Analysts | Tax Notes International

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Country by Country, Step by Step: Implementation Considerations for Country-by-Country Reporting by U.S. Multinationals, April 14, 2016

Bloomberg BNA | Tax Management Transfer Pricing Report

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Are You Considering an Advance Pricing Agreement? Companies Need to Conduct Benefit Analysis to Determine if APA Is Best Approach, January-February 2016

Tax Executives Institute | Tax Executive

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Country-by-Country Reporting: New Year, New Rules?, January 1, 2016

Bloomberg BNA | Daily Tax Report

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BEPS and Tax Transparency: KPMG Contacts
Have a question? Contact a member of KPMG’s BEPS and Tax Transparency Services team


 

Insight

Tax Challenges of Digitization

Insights from KPMG about the potential impact of proposed reforms on the taxation of the digital economy
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Insight

Income Tax Treaties, Agreements, and MLI

Information to assist multinationals apply income tax treaties to cross-border activities and transactions
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Insight

Global Tax Reform: BEPS and Tax Transparency as Drivers

Insights on the drivers of global tax reform affecting multinational companies
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