Trésorier/Treasurer magazine - N°88 - Jan/Fev/Mar 2015 - (Page 14)
This article describes the OECD's new recommendations on "Base Erosion & Proﬁt Shifting" (BEPS)
and to what extent these new rules, if they are adopted by the various states, will impact the dayto-day work of corporate treasurers. Can taxes and the treasury function still go together well?
BEPS will be certainly be THE next regulatory challenge that corporate treasurers will have to
confront. The tax landscape seems to be coming under ever greater ﬁre from governments. Looking
for the lowest tax charge is becoming a mineﬁeld for multinational corporations. Things will never
again be what they were; we can take that for granted, so we need to be ready to document intragroup transactions.
/ FEB / MAR 2015
do you have
LE MAGAZINE DU TRESORIER / TREASURER MAGAZINE
Transfer Pricing (TP)
Transfer pricing has always been given
special attention by the tax authorities.
However, since the financial crisis, the
G20 has added to its long regulatory
wishlist measures for preventing tax
avoidance through transfer pricing
between entities of the same group.
Clearly, excesses must have been committed. They used to be tolerated. But
the bailout of the banks and the sovereign debt crisis which arose from it have
forced states to look for new sources
of funds to wipe out their deficits. The
natural idea was to look for money wherever it happened to be and to curb the
excesses made possible by incorporating
exaggerated margins into transfer prices.
What could be simpler than transferring
income or margin within your group,
from a country in which deductions are
available to another country in which
there are no, or fewer, deductions.
The G20's three watchwords: SubsSimple and effective, but indefensible.
tance - Transparency -
The idea, then, is to ensure that these
abuses should not be committed and that
The three key words proclaimed by the
the substance should not be transferred
G20 are these: "substance" (which should
from one country
take precedence over
to another, thus
form, following the
The idea, then, is to ensure
states of badly needed that these abuses should not be of "substance over
revenue. The G20 has
committed and that the subsrecently reaffirmed
tance should not be transferred as regards intellecits support for the
tual property with
from one country to another,
OECD project on that
the expansion of
thus depriving certain states of digital businesses
subject, and also for
the "Action Plan" that badly needed revenue.
and an increasingly
it has put forward.
The OECD itself has
given the "Global Forum on Transparency
the post-financial crisis measures and
and Exchange of Information for Tax
regulations have the overarching objecPurposes" the task of working out the
tive of absolute transparency); and finally
bases of this new regulation.
"consistency" (consistency between
governments is required to avoid leaving
Table des matières de la publication Trésorier/Treasurer magazine - N°88 - Jan/Fev/Mar 2015
Table of contents
FINANCIAL HIGHLIGHTS Luxembourg Tax News
INTERVIEW From Legal Entity Management to Bank Account Management - LVMH case study
Treasurers, do you have any BEPS?
7 Ways to impress your CFO boss starting now
How to do more with less
Repo made easy
Comment combiner rendement, liquidité et gestion des risques pour sa trésorerie : l'exemple français
Les stratégies d'Alpha, à la rescousse d'un environnement de taux faibles
The benefits of collateral for the corporate treasurer
Les états financiers dans le cadre d'EMIR - que réserve l'avenir?
VAT changes as from 2015: new reimbursement procedure of VAT credit
Investissement des entreprises - une nouvelle ère pour la trésorerie
15 MINUTES AVEC USG Finance Professionals
THE RISK OBSERVATORY
LIFE BEYOND NUMBERS
Trésorier/Treasurer magazine - N°88 - Jan/Fev/Mar 2015