Base Erosion Profit Shifting


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  • Base Erosion and profit shifting refer to the tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift the profit to low or no tax locations. Under this framework, more than 100 countries and jurisdictions are cooperating to implement BEPS;

Base Erosion Profit Shifting

What is Base Erosion Profit Shifting?

The international tax system is changing rapidly due to coordinated actions by government and unilateral arrangements as designed by individual countries both are intended to tackle concerns over BEPS and perceive international tax avoidance technique of high-profile multinational organizations.



BEPS – TP Achievement Points

Based on the recommendation of BEPS and worldwide in-depth scrutiny by the tax authorities mainly involves intangible transactions. Tax authorities are likely to draw inference and support from OCED and BEPS guidelines to determine return from intangibles. These guides in how to analyze various Intellectual Property Rights, brands etc. and how they are positioned and whether all the group members contributing towards development, enhancement, maintenance, protection and exploitation of intangibles which helps to determine:

Documentation requirement for each MNE's conducting interstate transactions with their group companies

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