Tax Design and Administration in a Post - BEPS Era: A Study of Key Reform Measures in 18 Countries

Abstract

The OECD’s Base erosion and Profit Shifting (BEPS) initiative is undergoing what may be the most challenging phase, namely ratification and implementation by countries and jurisdictions. In this paper we provide a preliminary overview of the approaches being taken in 18 jurisdictions, namely: Australia, Canada, China, Hong Kong, India, Indonesia, Japan, Korea, Malaysia, the Netherlands, New Zealand, Nigeria, Singapore, South Africa, Thailand, the United Kingdom, the United States and Vietnam. When the larger project is complete in early 2019, it will enable the global accounting profession to be apprised of the effect of the enhanced tax reporting and compliance requirements under the G20/OECD BEPS program). The paper provides some background on each of the jurisdictions, prior to reviewing their position on the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), the BEPS Inclusive Framework and the adoption of the four minimum standards of Actions 5, 6, 13 and 14. The paper then reviews the responses to the remaining BEPS Action items, as well as outlining unilateral measures across these jurisdictions.