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Base Erosion Profit Shifting

Base Erosion and profit shifting apply to tax evasion tactics that manipulate loopholes and mismatches in tax rules to deliberately transfer profit to minimal or no tax locations. Within this setting, more than 100 countries and jurisdictions participate in the application of Base Erosion Profit Shifting.

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What does Base Erosion Profit Shifting mean?

The international tax structure is evolving increasingly owing to concerted action by the government and unilateral agreements developed by individual countries both to resolve BEPS issues and to view the international tax avoidance strategy by large-profile global companies.

What Assistance Base Erosion Profit Shifting provide?

  • This would help to define the overall objective of the MNE community on the basis of the BEPS regulations and will also help to comply with the new specifications resulting product wise.
  • We can also offer guidance in the evaluation of different intangibles, as well as in deciding how group members contribute to the development, preservation, security and abuse of intangibles that are properly valued in conjunction with the Significant People's Functions.
  • Monitor and assess the company's readiness and training for TP Enforcement and responsibilities and prepare the team to fulfill the compliance requirements in order to ensure consistency with local and global documents.


  • The OCED (Organization for Economic Cooperation and Development) introduced the BEPS Action Plan in July 2013 at the request of the G20 Finance Ministers
  • The Action Plan, with the aid of various reports, set of guidelines and suggestions would help prevent BEPS and allow the government to deal with domestic and international mechanisms that prohibit companies from charging little or nil taxes.

What are the achievements points of Base Erosion Profit Shifting?

On the basis of the BEPS guideline and a regional in-depth analysis by the tax authorities, this mainly involves intangible transactions. Tax authorities are likely to draw inferences and guidance from the OCED and BEPS recommendations for the assessment of intangible taxes. Such guides discuss how to assess the various intellectual property rights, trademarks, etc., and how they are placed, and whether all the members of the group contribute to the development, improvement, preservation, security and abuse of intangibles which help to determine the status of intangibles:

  • Placement of Intellectual Property Rights and Position of Conception and Creation of IPR
  • Legal possession or advantageous control of intangibles and associated transactions
  • Three Tier TP documents comprising country-by-country information: as suggested by the OCED, three-tier data includes consistency in reporting, which implies:
  • Applicability to all Multinational enterprises whose predominant parent is residing in countries to which the Organisation for Economic Co-operation and Development / G8/G20 Regulations relate.
  • Needs a description of the international structure of the MNE
  • Recognize whether the revenues and profits produced by all jurisdictions are adequate to the content.
  • Predict artificially moving the considerable amount of income to a beneficial location with tax benefits by automated exchange of information between tax authorities
  • Recognizing the position of communities where they benefit from tax benefits

What Documents are required for each Multinational enterprises performing interstate transactions with their group companies

  • Master folder to provide a template for the Multinational enterprises.
  • Local report to provide the content Transfer Pricing locations of the international agency to its international partners.
  • In order to offer jurisdiction wise information, Country-by-country reporting is required.

What are the main services offered by us?

Below mentioned are the services which are offered by us to our clients

  • Undertake learning which would involve exchange of information sessions and raise understanding of the three-tier record-keeping¬†standards for its development and compliance parameters.
  • Undertake a clinical review to help the scheduling of Transfer Pricing compliance responsibilities.
  • Reviewing intangibles on the grounds of the Base Erosion Profit Shifting guidance to insure that the members of the group influence the development, preservation, protection and use of intangibles and are appropriately remunerated.
  • Develop execution protocols and procedures and train the group members to satisfy reporting requirements and remain consistent with local and global documents.

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