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. - N°88 - JAN / FEB / MAR 2015 Treasurers, do you have any BEPS? LE MAGAZINE DU TRESORIER / TREASURER MAGAZINE Transfer Pricing (TP) 14 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 - Consistency 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 depriving certain The idea, then, is to ensure sacrosanct principle states of badly needed that these abuses should not be of "substance over revenue. The G20 has form", particularly 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. virtual economy); The OECD itself has "transparency" (all 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

Cover
Table of contents
EDITORIAL
FINANCIAL HIGHLIGHTS Luxembourg Tax News
INTERVIEW From Legal Entity Management to Bank Account Management - LVMH case study
FOCUS
Treasurers, do you have any BEPS?
Reguvolution
7 Ways to impress your CFO boss starting now
FORUM
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
CORPORATE FINANCE
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
NEWS
LIFE BEYOND NUMBERS

Trésorier/Treasurer magazine - N°88 - Jan/Fev/Mar 2015