Base Erosion and Profit Sharing (BEPS) Action Plan: Changes to the International Tax System

In November 2015, Prime Minister Justin Trudeau and the other G20 leaders endorsed the OECD’s package of measures released as part of the base erosion and profit shifting (BEPS) project. The BEPS project, an ambitious plan undertaken jointly by the OECD and G20 to overhaul the global international tax system, culminated in hundreds of pages of recommendations that, if adopted, could have a significant impact on cross-border trade and the competitiveness of Canadian businesses.

Lawyers in Osler’s leading Tax Group are experts on the complexities of international taxation and understand the challenges of a rapidly changing global economy. Here they offer timely insight into global tax reforms and the ongoing developments of the OECD/G20 BEPS Action Plan.

As the Action Plan unfolds, Osler will continue to provide updates on the impact of the plan initiatives. Continue to visit this page for useful information.

BEPS Actions Implementation - Canada

This chart is an overview of the 15 action items, outputs and resources that we have curated to provide you with detailed information for each action item. Click on an action item below to access the information.

Selected Resources

Controlled Foreign Company Rules (CFC Rules)

Summary

Designing Effective Controlled Foreign Company Rulesrecommendations to strengthen rules of CFC’s.

Output

Domestic Law

Selected Resources

Summary

Measuring and Monitoring BEPSMethodologies to collect and analyse data on BEPS and the actions to address it.

Output

Recommendations/TPG

Selected Resources

Background on the BEPS Action Plan

To better understand the background behind the OECD/G20 BEPS Action Plan, we have a few videos that outline the shifts in the international tax system and global reactions to the plan.
 

OECD, G8 and G20 Study − Changes Ahead to the International Tax System

Patrick Marley, Taxation Partner, discusses shifts in the international tax system (July 2013)

 

Richard Tremblay, Taxation Partner, discusses the shift in the international tax system (July 2013)


 

International Reaction to the OECD Action Plan

Patrick Marley, Taxation Partner, comments on International Reaction to the OECD Action Plan (November 2013).

 

Key Contacts

Patrick Marley

Patrick Marley
pmarley@osler.com
tel: 416.862.6583

Matias Milet

Matias Milet
mmilet@osler.com
tel: 416.862.6648

Drew Morier

Drew Morier
dmorier@osler.com
tel: 416.862.5971

Amanda Heale

Amanda Heale
aheale@osler.com
tel: 416.862.6780

International Tax Planning

Canadian and multinational clients engaged in international transactions rely on Osler to provide timely tax planning and liability management advice.

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Transfer pricing

OECD transfer pricing guideline amendments, the influence of BEPS and interest in tax arbitrage has increased scrutiny of transfer pricing policies and strategies.

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