The BEPS Action Plan concerns many areas from multinational companies’ financing methods to operational structures, and their impact on companies can be summarized as follows:

  • Companies are subject to certain restrictions in terms of borrowing, including financing from third parties.
  • The principle of sharing the earnings arising from the intangible assets of the multinational group of companies on the basis of legal and economic ownership has been introduced.
  • Due to some of the activities of the companies, while the exemptions for permanent establishment are narrowing, the concept of permanent establishment has expanded.
  • Significant obligations have been imposed on companies, especially in terms of transfer pricing documentation.
  • With the changes made in tax agreements, the tax burdens of multinational companies are expected to change, and the risk of double taxation has increased more than the previous periods.
  • Companies are obliged to notify tax authorities before tax planning was made.
  • In order to ensure automatic information exchange, companies must notify tax authorities about their operations all over the world.

The Action Plan may require companies, including holding structures, to reorganize their multinational structures and operational models. In this context, we can support you on the following issues:

  • Optimization of the operation model
  • Establishment or reorganization of the holding structure
  • Investigation and exposure of permanent establishment risk
  • Investigation of the controlled foreign company (CFC) income issue
  • Limitations on the reduction of interest expenses
  • Improvement of transfer pricing practices
  • Indirect taxes
  • Other BEPS issues

We have an experienced team of consultants who can evaluate your needs and offer the most relevant and appropriate solution for your organization's needs.

Request Consulting