October 5, 2015 – The Organisation for Economic Co-operation and Development (OECD) has issued the BEPS 2015 Final Reports
on all 15 action items addressing base erosion and profit shifting (BEPS).
These reports detail all of the recommendations that were developed by OECD and the G20 countries over the past two years regarding proposed changes to the international tax rules, including transfer pricing rules, permanent establishment status, the interest deductibility rules, controlled foreign affiliate rules, rules to prevent hybrid mismatch arrangements and limitations on tax treaty benefits. Also included is a new two-tier approach to transfer pricing documentation and a country-by-country reporting requirement.
Further details will be announced in due time.