Forum on Implementation of Measures to Counter Base Erosion Profit Shifting (BEPS)

Erika Szabó's picture
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On 6th-8th December 2022, IOTA successfully hosted the 7th IOTA Forum on Implementation of Measures to Counter Base Erosion Profit Shifting (BEPS) in Budapest, Hungary. The hybrid event was joined by high-ranking officials from our international partner organisations and the business community along with over 40 participants from 28 IOTA member tax administrations gathering personally at the venue and more than 120 attendees connecting online to the new experience.

The Forum on BEPS explored strategies, methods, approaches and best practices adopted to counter various BEPS challenges facing by tax administrations. The three-day event offered opportunities for its members to work collaboratively towards meeting the emerging challenges of implementing the BEPS measures. The Forum is an important platform for experts of IOTA member tax administrations to discuss and share strategies and practical application of working methods and tools developed to effectively tackle BEPS.

On the first day of the Forum on BEPS, speakers from our international partner organisations and the business community such as Jeff Mitchell (OECD), Alison Lobb (Deloitte UK), along with Lucia Barone (KPMG Italy) opened the floor for discussion on tax challenges arising from the digitalisation of the economy. The main focus was on Pillar 2, specifically on the GloBE Rules issues, through receiving feedback from MNE’s regarding the implementation of Pillar 2 solutions. Additionally, on another session, participants got better acquainted with emerging transfer pricing issues such as consequences following the Covid-19 pandemic and pricing of financial transactions.

During this session various country presentations reflected on:

  • Transfer Pricing and Covid-19 Consequences presented by Vincenza Genovese, Italy
  • Covid-19 challenges to TP Set-Ups presented by Simon Hofstätter and Branko Neumann-Vukovich, Austria
  • Unilateral APA on Financial Transactions: Swiss Federal Tax Administration perspective presented by Natassia Burkhalter-Martinez, Switzerland
  • Determining the true substance of an advance made to an entity by an associate presented by Ilia Baghaturi, Georgia

The second day of the Forum on BEPS brought another group of fascinating presentations on the stage and aimed at discussing more practical areas of Country by Country Reporting issues e.g., practical and effective usage of CbC reporting data; process of internal dissemination of the report; confidentiality issues; and IT tools developed for automatic process of CbCR data with the following presentations:

  • Use of CbCR for risk assessment in Norway presented by Ola Holdal, Norway
  • Transfer Pricing Risk Assessment Process in CbC Reporting presented by Dana Slivkova, Slovakia
  • Effective use of CbCR data presented by Vito Furnari, Italy
  • CBC Reporting, the Swedish approach and experience presented by Roberth Glansberg, Sweden
  • CbCR in practice – Data exchange and related risks in Croatian Tax Administration presented by Davor Burić, Croatia

The last day of the Forum on BEPS continued the topic started yesterday on exploitation of CbCR data, and also discussed best practices on approaches followed by IOTA tax administrations on the effective use of Mandatory Disclosure Rules exchanging data exploring country examples on DAC4 and DAC6 usage of data – Slovenian experience delivered by Dominik Kuzma, Slovenia and a Spanish experience with DAC6 reports presented by Iñaki Olabarrietta, Spain. Finally, the last theme of the plenaries dealt with an internally developed software by the Korean Tax Administration focused on a more efficient  Tax/TP analysis based on the utilisation of Local/Master File data. This topic was displayed by Inyoung Ko, Republic of Korea.

During the three-day Forum Meeting attendees were actively involved in group discussion sessions, where they could exchange their views, experiences, raise questions and jointly look for solutions in transfer pricing and CbCR areas. The presentations and the recordings of the event will be made available soon for registered IOTA website users on the event’s webpage.