International Tax Law: The New BEPS Tax Convention
Implementation of a global tax convention referred to as BEPS (Base Erosion and Profit Shifting) by German tax legislation is largely finished. The OECD’s BEPS plan of action entails a large number of far-reaching changes to international tax law. All multinational groups of companies are affected. But the tax convention also brings considerable changes for SMEs. In principle, the convention is to ensure that profits can be taxed where they are earned. In future, so-called ‘hybrid arrangements’ and the creation of so-called ‘untaxed income’ will be prohibited. Furthermore, the term of ‘permanent establishments’ is redefined. This is designed to prevent permanent establishments being constructed solely for advantageous tax purposes.
We at HANSA PARTNER will help you in complying with the legislator’s new requirements and support you in the practical implementation of the BEPS plan of action.
In cooperation with our partners in the international BKR network, we also offer the following services:
- Drawing up transfer price documentation
- Defending transfer pricing within the context of audits
- Avoiding permanent establishment taxation
- Minimising risk in function relocation