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Base Erosion and Profit Shifting (BEPS)

G-20, OECD and the EU have heavily increased the number of initiatives that discourage Base Erosion and Profit Shifting (BEPS).

MLI matching overview
Article - 27 June 2017

MLI Matching Overview

What are the choices made by the Netherlands, Belgium, Luxembourg and Switzerland on the multilateral instrument (MLI) signing? Check our overview.
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Overview: MLI choices made by the Netherlands, Belgium, Luxembourg and Switzerland
Article - 15 June 2017

Overview: MLI choices made by the Netherlands, Belgium, Luxembourg and Switzerland

What are the choices made by the Netherlands, Belgium, Luxembourg and Switzerland on the multilateral instrument (MLI) signing? Check our overview.
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Launch of multilateral treaty (MLI) to implement BEPS measures
Article - 25 November 2016

Launch of multilateral treaty (MLI) to implement BEPS measures

On 24 November 2016, a group of more than 100 jurisdictions concluded negotiations on a multilateral instrument (MLI) that will modify the application of existing...
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Political agreement EU to implement anti tax avoidance measures (Anti Tax Avoidance Directive)
Article - 21 June 2016

Political agreement EU to implement anti tax avoidance measures (Anti Tax Avoidance Directive)

Monday 20 June 2016 at midnight the EU Council reached political agreement on the Anti Tax Avoidance Directive (ATAD). The ATAD will be formally adopted in a...
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MLI matching overview

MLI Matching Overview

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Our expert BEPS team can help you

Internationally operating companies therefore need high-end strategies to create an effective tax structure. Such strategies need to consider all regulatory developments and acknowledge the change in the international tax climate. Our expert BEPS team can help you to design an international tax strategy and implement optimal solutions.

Your BEPS team: on top of the latest regulatory developments

New regulations are deployed at a rapid pace. This means that you need a team that is on top of the latest developments. Our multidisciplinary team of experts monitors the following developments closely:

  • Fundamental changes to transfer pricing rules;
  • Limitation of base erosion via interest deductions and other financial payments;
  • The EU’s Anti-Tax Avoidance Package / Directive (ATAD);
  • Transparency measures (country-by-country reporting, exchange of tax rulings between EU Member States, mandatory disclosure rules, the introduction of the UBO register, etc.);
  • Changes to double tax treaties and the multilateral instrument (MLI);
  • State aid issues;
  • Proposals for the taxation in the Digital Economy
  • Proposals for an EU Common Corporate Tax Base (CCTB) and an EU Common Consolidated Corporate Tax Base (CCCTB).

Our advice will always weigh the impact of public opinion on your reputation, while tackling the major tax hurdles. Our BEPS team cooperates with our competition lawyers, state aid/EU tax law experts, litigators and transfer pricing experts, in order to provide you with the best integrated solution for your company.

Our services

We advise on and review the impact for multinationals of: 

  • The various BEPS measures;
  • Fundamental changes to transfer pricing rules;
  • Limitation of base erosion via interest deductions and other financial payments;
  • The EU’s Anti-Tax Avoidance Package / Directive (ATAD);
  • Transparency measures (country-by-country reporting, exchange of tax rulings between EU Member States, mandatory disclosure rules, the introduction of the UBO register, etc);
  • The General Anti-Avoidance Rule (GAAR);
  • Changes to the double tax treaties;
  • The multilateral instrument (MLI);
  • Holding structures;
  • Group financing;
  • IP structures;
  • Hybrid mismatches.
  • Proposals for the taxation in the Digital Economy
  • Proposals for an EU Common Corporate Tax Base (CCTB) and for an EU Common (Consolidated) Corporate Tax Base (C(C)CTB)