OECD Tax Talk #2 - BEPS

In July 2016, Pascal Saint-Amans, Mayra Lucas, Advisor of Transfer Pricing Unit, Melinda Brown, Advisor of Transfer Pricing Unit, and Achim Pross, Head of International Co-operation and Tax Administration, have again held a webinar about the current development of the BEPS Project. Thereby, the newest works regarding individual action points have been expanded on.

Short summary

The OECD has got three new discussion drafts regarding the adjustments of the guidelines for Transfer Pricing. Besides the correction of purely formal inconsistencies of the existing guidelines regarding the adopted BEPS package, especially substantive amendments regarding the profit-split-method, the profit allocation of permanent establishments and the deductibility of interests have been published to the BEPS Project.

Regarding the exchange of tax rulings (action point 5), Achim Pross has presented a scheme which regulates in detail the framework conditions and requirements of the exchange between states and schematically outlines the process.


The second webinar from the 12th July attests that the implementation of the package of measures regarding the BEPS is progressing with high cadence. The different specifications are important steps in the implementation of the BEPS package and will lead to an increased legal security. Good predictability regarding compliance costs creates acceptance with the corporations and is a positive signal to the economy.