IOTA Secretariat
IOTA Forum on Implementation of Measures to Counter Base Erosion Profit Shifting (BEPS)
On May 21-22, 2025, IOTA launched another insightful hybrid technical event under the IOTA 2025 Work Programme: the Forum on Measures to Address Base Erosion and Profit Shifting (BEPS). We were delighted to host 19 tax officials from 14 IOTA member tax administrations in Budapest, Hungary, along with over 100 online participants from 25 IOTA member tax administrations. Additionally, we were pleased to have delegates from one of our international partner organisations, the Organisation for Economic Co-operation and Development (OECD).
The IOTA Forum on BEPS aimed to create a collaborative environment for IOTA member tax administrations to tackle the challenges arising from the application of BEPS measures. This Forum served as an invaluable opportunity for tax administration experts to exchange ideas, discuss strategies, and share practical tools necessary for effectively addressing BEPS. Over the two days, representatives from various IOTA member countries, including Austria, Azerbaijan, Belgium, Denmark, Hungary, Italy, Spain, and the United Kingdom, have delivered presentations on the topic.
On the first day of the Forum, participants received updates from the OECD’s Laura Stefanelli regarding ongoing initiatives and recent advancements in the OECD/G20 Inclusive Framework on BEPS. The focus was on the Two-Pillar Solution aimed at addressing tax challenges from the digital economy, as well as the progress made over the last decade in implementing the four minimum standards of BEPS. Furthermore, attendees enjoyed presentations from Denmark, Hungary, Italy, and the UK.
- United Kingdom: ‘CbC/Outcomes of the CbCR Sub-Working Group’ presented by Simon Kimber (online presentation);
- Hungary: ‘CbCR and Safe Harbour’ presented by Imola Boróka Vasas;
- Denmark: ‘Various Issues Affecting the Tax Dispute Process’ presented by Bo Darling Larsen (online presentation);
- Italy: ‘Ensure Access To MAP(S): Issues and Possible Solutions’ presented by Benedetta Tomasi.
Group Discussion sessions also allowed participants to share and exchange views on the practical aspects of Country-by-Country (CbC) Reporting and various issues affecting Mutual Agreement Procedures.
The second day of the IOTA Forum on BEPS also featured a range of enlightening presentations. Participants focused on business restructurings, including the transfer of intangibles and specific considerations that should be made following the restructuring, as well as transfer pricing challenges learned from presentations by IOTA member countries such as Austria, Azerbaijan, Belgium, and Spain.
- Austria: ‘Restructure. Separate. Profit.’ Co-presented by Katrin Frank & Andreas Kallina;
- Belgium: ‘Shifting from Fully Fledged to Limited Risk Distributor’ presented by Filip Haes (online presentation);
- Spain: ‘TP Financial transactions, a specific case’ presented by Israel Muñoz Díaz;
- Azerbaijan: ‘BEPS and transfer pricing in Azerbaijan’ presented by Chingiz Musayev.
As on the previous day, following the plenary sessions, attendees engaged in group discussions covering practical aspects of business restructuring and transfer pricing. All the materials, presentations, and photo gallery are now available online on the event’s webpage, as well as the video recording of the event. This event was facilitated by IOTA International Taxation Expert Alexandros Roukalis with support from his colleague Massimo Morarelli.
