Abstract
In order to eradicate the unfair competition in the form of tax avoidance and profit shifting, the OECD and the EU advise undertaking effective measures, which have been gathered in a complex of 15 actions that should be introduced by member states to their law orders. Promoting the automatic information exchange and reporting (BEPS 13) has become one of the priorities, as it is considered a tool that guarantees the transparency of actions and the future European and international standards in tax matters. Due to the fact that groups of multinational enterprises have the possibility for applying practices of aggressive tax planning, tax organs of member states need extensive and accurate data that will enable them to react to harmful tax practices by introducing amendments to law or implementing appropriate risk assessments and tax inspections. A greater transparency towards tax organs ought to result in multinational tax organs refraining from the practices they have implemented so far, so that they would start to pay taxes in the country they generate income.
Highlights
BEPS1 is a term used in an international debate concerning tax avoidance and measures towards countering the unfair underpaying of public levies, which has gained popularity due to the OECD Report, known and referred to as the
Adopted in the documents of the Organisation for Economic Co-operation and Development (OECD), the term “BEPS” refers to the tax planning strategy, the major objective of which is to make use of legal loopholes and contradictions of tax regulations for the purpose of hiding profit or transferring it to places, in which a taxpayer is active in a small extent or does not run any activity at all, yet where taxes are low when compared to the taxpayer’s domicile, or where are none
The reporting obligations imposed on the groups of affiliated entities are costly and time-consuming
Summary
BEPS1 is a term used in an international debate concerning tax avoidance and measures towards countering the unfair underpaying of public levies, which has gained popularity due to the OECD Report, known and referred to as the. C country prepared in such a way is obliged to transfer this report – within the framework of the automatic information exchange and in due time – to each member state, in which – as can be seen from the information included in the report by country – the tax resident is at least one entity of the multinational enterprise groups, to which the reporting entity belongs, or in which the business activity carried out by its permanent establishment is levied taxation. A sample table including the required data pursuant to Point 8 § 1 of the Decree is presented in the Annex
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