The final package of the Organisation for Economic Co-operation and Development’s base erosion and profit shifting (BEPS) measures includes new minimum standards on country-by-country reporting; treaty shopping; curbing harmful tax practices; and effective mutual agreement procedures.

 

The package also revises the guidance on the application of transfer pricing rules to prevent taxpayers using so-called “cash box” entities to shelter profits in low, or no-tax jurisdictions. It redefines the key concept of permanent establishment to curb arrangements that avoid the creation of a taxable presence in a country by reliance on an outdated definition.

 

It offers governments a series of measures to be implemented through domestic law changes. These include strengthened rules on controlled foreign companies, a common approach to limiting …