BEPS: Collection of KPMG Insights

Insights by date from KPMG on BEPS, tax transparency, and more

Manal Corwin

Manal Corwin

Principal in Charge, Washington National Tax, KPMG US

+1 202-533-3127

Brett Weaver

Brett Weaver

ESG Tax Leader, KPMG US

+1 206-913-6697


Latest insights

A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow

October 5, 2022

The widespread implementation of the OECD’s Pillar Two Global Anti-Base Erosion (GloBE) rules is now a strong probability This episode of KPMG Inside International Tax discusses the many pitfalls that these rules may present to taxpayers currently engaging in M&A transactions.

Future of the Arm's-Length Principle

September 26, 2022

In a series of three articles, which appeared in Tax Notes International, the authors assess the merits of the arm's-length principle and the significant problems with global formulary apportionment—the perceived alternative. They also consider the impact that the BEPS 2.0 project and other OECD initiatives may have on the future of transfer pricing.

Where Did Pillar One and Pillar Two Come From?

August 25, 2022

The impacts of Pillar One and Pillar Two on transfer pricing vary by jurisdiction, taxpayer, and the likelihood of ultimate adoption. This KPMG Exploring Transfer Pricing podcast provides a high-level overview of the two pillars, a starting point for understanding the possible implications for transfer pricing.

Amount B: The Forgotten Piece of the Pillar 1 Jigsaw

July 11, 2022

This article, which appeared in Tax Notes International, examines a significant but frequently overlooked piece of the OECD’s Pillar 1 proposal, Amount B. The KPMG authors explain how Amount B could work, discuss implementation challenges, and consider how businesses can prepare.

The Diverging Paths of Pillars 1 and 2

July 4, 2022

In this article, which appeared in Tax Notes International, the KPMG authors examine the status of the OECD’s two-pillar approach to modernizing the international tax system and consider the international implications of the different paths countries are taking to implement Pillars 1 and 2.

The Future of Consumer and Retail - A Tax Perspective

June 2022

Consumer and retail companies are revisiting their e-commerce and direct-to-consumer methodologies with large-scale digital transformations and targeted customer centric considerations. All consumer and retail companies investing in e-commerce should revisit their operating models and structures to help ensure they are properly addressing the relevant tax implications and potentially unlocking tax value.

How Can You Master the Master File?

April 18, 2022

This KPMG Exploring Transfer Pricing discusses the importance of a well-prepared Master File, the “bass line” for global transfer pricing documentation, for which the OECD prepared guidelines as an output from the BEPS action plan.



More recent articles , podcasts, and more

More recent articles, podcasts, and more

Archive (2016-2021)

2021

2020

October 12, 2020 | KPMG Report: Summary and Initial Analysis of Pillar One Blueprint

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October 12, 2020 | KPMG Report: Summary and Initial Analysis of Pillar Two Blueprint

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August 31, 2020 | The State of Country-by-County Reporting | Tax Notes International

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August 26, 2020 | It's Complicated — It's Really Complicated (DAC6) | Thomson Reuters Tax & Tech Talks podcast

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July 31, 2020 | INSIGHT: Transfer Pricing Substance in Flux — DEMPE, BEPS 2.0, and COVID-19 | Bloomberg Tax

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February 13, 2020 | KPMG Report: Insights on OECD's Revised "Unified Approach" to Tax Challenges of Digitalisation

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February 13, 2020 | KPMG Report: OECD Transfer Pricing (Final) Guidance on Financial Transactions: Initial Impressions

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January 2020 | Managing the Uncertainty of Digital Taxation | KPMG CTO Insights — Spotlight Edition

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2019

December 2019 | OECD's Unified Proposal on Pillar One Poses Challenges for Dispute Resolution | International Tax Review

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November 11, 2019 | BEPS 2.0 Unpacked:  What you should know about the OECD's current effort to modify the global taxing rules for multinational companies | KPMG video

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November 2019 | Global Glare: International Tax Reform Steals the Spotight | KPMG CTO Insights

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October 21, 2019 | INSIGHT: Taxing the Digital Economy – As Simple as "A, B, C"? | Daily Tax Report

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October 9, 2019 | KPMG Report: CFC Rules under ATAD – Overview and Implementation Status

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September 2019 | Digital Taxation: International Focus, Individual Doubt | KPMG CTO Insights – Issue Spotlight 

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August 13, 2019 | INSIGHT: Cost-Plus Transfer Pricing for Marketing Support Services between BEPS 1.0 and BEPS 2.0 | Daily Tax Report

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August 8, 2019 | KPMG Report: Corporate Tax Transparency in the BEPS Era – Tax Departments in the Spotlght

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July 3, 2019 | KPMG Report: BEPS for Asset Management – Changing International Tax Landscape

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June 13, 2019 | KPMG Report: BEPS Action 8–10 – Current State of Play

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May 11, 2019 | KPMG Report: Taxation of the Digitial Economy – 2019 to Be a Pivotal Year

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May 6, 2019 | The U.S. Proposed Digital Services Tax | KPMG In Dispute podcast 

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May 2019 | Potential Impact of the Taxation of the Digital Economy | KPMG Video

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May 2019 | BEPS, DEMPE & Defending Your Value Chain | KPMG Video

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April 19, 2019 | OECD's Proposals on Taxing the Digital Economy: A look at the OECD's proposals and how they compare to prior efforts

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February 2019 | CTOs and the Taxatio of the Digital Economy | KPMG CTO Insights

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2018

July 12, 2028 | OECD Super Treay Enters into Force July 1: A Primer | Tax Management Transfer Pricing Report

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May 2018 | The BEAT and Bilateral Tax Treaties: Where Might the Tension Lead | ABA Tax Times

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February 16, 2018 | BEAT's Impact on Transfer Pricing Alternative Dispute Resolution | Daily Tax Report

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February 2018 | Across the Line: Navigating Global Tax Challenges | KPMG CTO Insigths

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2018 | KPMG Report: Post-BEPS Tax Controversy—Preparing for New Rules, New Risks

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2017

August 11, 2017 | Understanding the Operation, Impact, and Practical Implications of the MLI | Tax Management International Journal

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

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2017 | OECD Master File Considerations: North America | Expert Guides, Transfer Pricing Advisers

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June 1, 2017 | Ten Questions on the OECD's DEMPE Concept and Its Role in Valuing Intangibles | Tax Management Transfer Pricing Report

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

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March 2017 | Treaty Benefits for Investment Vehicles in a Post-BEPS World | Taxes, The Tax Magazine

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2017 | KPMG Report: Enhancing Value in a Disruptive Environment

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2017 | KPMG Report: The BEPS Ripple Effect, Multinationals Are Reevaluating How and Where They Do Business

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2016

September-October 2016 | Country-by-Country Reporting: Identifying the Elephant | International Tax Journal

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July 26, 2016 | Country-by-Country Reporting: Are We There Yet?, | Daily Tax Report

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July 14, 2016 | Transfer Pricing for Financial Transactions: Determining Credit Ratings | Tax Management Transfer Pricing Report

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May 18, 2016 | KPMG Report: 2x4 Approach to Country-by-Country Reporting

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May 2, 2016 | The Post-BEPS World of Permanent Establishment | Tax Notes International

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April 14, 2016 | Country by Country, Step by Step: Implementation Considerations for Country-by-Country Reporting by U.S. Multinationals | Tax Management Transfer Pricing Report

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

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January 1, 2016 | Country-by-Country Reporting: New Year, New Rules? | Daily Tax Report

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