The BEPS project addresses forms of tax treaty abuse consisting of arrangements that “erode” the tax base or that avoid tax through profit shifting, hence “Base Erosion and Profit Shifting” (BEPS). To this end, the OECD issued a Discussion Draft on 14 March on Preventing the Granting of Treaty Benefits in Inappropriate Circumstances. The Draft proposes to deal with the problem by means of a new combined test for eligibility for treaty benefits, consisting of a “limitation on

In February 2014, the OECD published a draft template for country-by-country (CBC) reporting of the allocation of income, taxes and business by multinational companies under the BEPS initiative. This was in response to an Action Plan released in July 2013 calling for a review of existing transfer pricing documentation rules and the development of a template for CBC reporting of income, taxes and business activity for tax administrations. The draft template requires a company