With the 15 actions of its project to prevent Base Erosion and Profit Shifting (BEPS), the OECD wants to put a stop to aggressive tax planning. Among other things, the measures demand more transparency, for example, through revised transfer pricing documentation requirements. The expansion of the concept of a permanent establishment is expected to lead to a large number of new permanent establishments.
Whether major groups or medium-sized enterprises, all internationally active companies must adapt to these new conditions. Since the German Federal Government has already started to actively implement a number of these actions, we must now analyse existing structures, projects and processes and prepare any adjustments.
Tax risks due to unrecognised permanent establishments can have serious negative consequences for companies and their executive bodies. Companies should therefore now be analysing in which areas preventative measures should be taken and how optimisation potential can be identified by using IT tools.
Overview of all 15 actions:
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