Base erosion and profit shifting (BEPS) project and its effect on transfer pricing

Absztrakt (kivonat)

With the rapid transformation from industrial to digital economy, Multinational companies (MNCs) play a more important role in the global economy and there is an increasing proportion for intracompany transaction out of global trade, from which large MNCs have more and more opportunities to shift their profit to lower or non-tax countries in order to reduce their taxable income by taking tax advantage of loopholes of the current international tax law. Base Erosion and Profit Shifting (BEPS) project is established to remedy the loopholes of the current international taxation law to prevent tax avoidance from being conducted by most of MNCs. This project has been implemented by many countries. However, it is still in the initial stages of the implementation. This thesis aim to analyze the implementation of BEPS Action Plan in terms of transfer pricing focusing on Action (13) and Actions (8-10) based on practical analysis of the current responses from both the participating countries according to some surveys that have done before and the MNCs by taking sample of 30 MNCs and study the trend of the gap between the statuary and effective tax rate in three time periods 2011,2013 and 2015. Most of the OECD countries has started to implement all four-action plan while almost half of developing countries still hesitate to reform their tax policies according to the requirements of BEPS Action Plan. In the case of company analysis, there aren't significant changes about their tax planning in these three years due to the possible consequences that this action plan will bring about more costs for big MNCs in many aspects such as operational cost, information discloses, etc... Based on the practical analysis, the implementation of this project still faces a great challenge, and it requires more coordination and cooperation among the international organization, national government, and the MNCs.