Base erosion and profit sharing (BEPS) recent developments and implementation: Countries are not only welcome but some have gate-crashed the BEPS party to stake their claim on their share of the "untaxed or minimally-taxed revenue"

Tax Law

With OECD’s presentation of the final reports on the 15-point Action plan to tackle BEPS and G20’s endorsement of these reports, each country is now racing to consider which recommendations to implement and how to implement them -- the goal being to create more revenues back home. There is enthusiastic support for the multilateral instrument to modify bilateral tax treaties (Action 15) since it tackles in a consistent and efficient manner tax treaty related BEPS measures on hybrids (Action 2), treaty abuse (Action 6), PEs (Action 7), and dispute resolution (Action 14); it is targeted for signature by 31 December 2016. Countries are selectively implementing the other BEPS Action Plans by domestic law or as a protocol to their bilateral tax treaties. Hovering over these BEPS developments is the EU State aid rule that Ireland gave illegal tax benefits to Apple of up to €13 billion. A speaker from EU will discuss the EU State aid ruling. Then the panel of speakers will discuss their countries’ reaction to the BEPS initiatives including the EU State aid ruling, the do’s and don’ts from such reaction, and how they hope to harvest that goldmine of “untaxed or minimally taxed revenue”.


  • William Maclagan, Blake, Cassels & Graydon LLP


  • Julie H. Cheng
  • Alexis Katchourine, Lerins Jobard Chemla
  • Saravana Kumar, Lee Hishammuddin Allen & Gledhill
  • Mahesh Kumar
  • Jay Shim, Lee & Ko
  • Picharn Sukparangsee, Bangkok Global Law Offices Limited
  • Jarrod Walker, Bell Gully
  • Ruby Rose Yusi, Angara Abello Concepcion Regala & Cruz Law Offices


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NZ Law Society

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