BEPS presentation -Final - Copy

KPMG BEPS Action

Plan Informative

Discussion

CFO India Network

27th November 2014

Areas of discussion

Tax Morality and Transparency1 3

OECD BEPS Action Plan3 9

Action 1 – Addressing the tax challenges of the digital economy4 15

Action 2 – Neutralizing effects of hybrid mismatch arrangements5 21

Action 6 – Preventing the granting of treaty benefits in inappropriate

circumstances6 26

Action 15 – Developing a Multilateral Instrument to Modify Bilateral Tax

Treaties7 29

Need for Base Erosion Profit Shifting Action Plan- ‘BEPS’2 6

Action 5 – Countering harmful tax practices more effectively, taking into

account transparency and substance8 31

Action 8 – Transfer Pricing aspects of intangibles9 33

Action 10 – Transfer Pricing aspects – low value-add intra-group

activities10 40

Action 13 – Transfer Pricing Documentation and country-by-country

reporting11 45

Tax Morality and

Transparency

© 2012 KPMG, an Indian partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International, a Swiss cooperative. All rights reserved.

© 2014 KPMG, an Indian Registered Partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. 3

OECD – BEPS 2014Tax Morality and Transparency

Do taxpayers have a “moral duty” to pay

their “fair share” of taxes?

Should corporations show what they are

contributing to society via tax payments?

Not merely a theoretical tax debate



OECD – BEPS 2014Tax Morality and Transparency …continued

Media

Board

Share-

holders

NGOs

Lobbyists

Communities

Government

Tax systems have not kept up

with changes in business

model

Governments under significant pressure to reduce deficits

Simultaneously, countries compete for profitable investment considering tax rates

Reducing the “Tax Gap” – Underground Economy versus the Multinationals

Citizen pro tax fairness keeping the spotlight on

this issue

Customers’ negative

perceptions, particularly of

household retail namesThe Tax

Debate Customers /

Suppliers

Need for Base

Erosion Profit

Shifting Action plan-

‘BEPS’



OECD – BEPS 2014Need to Curb BEPS – Some Insights

One of Fortune 500 US based company

Pre-tax

Income ($b)

Pre-tax

contribution

%

Employee

Nos. %

Customers

%

Effective

Tax Rate

US 10.20 30% 67% 39% 46%

Ireland 22.00 64% 4% 1% 0.06%

Others 2.00 6% 29% 60% 29%

With 4% employees

and 1% customers-

Ireland contributes

to 64% to US based

Company’s Profit



OECD – BEPS 2014Tax planning or evasion or management ??

Double Irish Dutch Sandwich

Avoidance of

Withholding tax

owned by C in favour

of B

No withholding tax

on royalty payments

made to entities

based in Netherlands

C can charge royalty

paid to D against its

profit

B is the resident of

tax haven and hence

no tax is attracted on

Royalty received

Ultimately Profit

shifted to a

jurisdiction with no

significant tax rate



OECD – BEPS 2014Tax Heavens – benefits of being low/no tax jurisdiction

Four key factors to define a “tax haven”:

a) No or nominal tax on relevant income

b) Lack of effective exchange of information

c) Lack of transparency

d) No substantial activities

The cumulative profits of different countries

recorded in various tax havens represents a

substantial part of those countries GDP

Tax Havens CFC profits as a % to

GDP

Bahamas 43.30%

Bermuda 645.70%

British Virgin Islands (‘BVI’) 354.70%

Cayman Islands 546.70%

Jersey 35.30%

Liberia 61.60%

Luxembourg 18.20%

Marshall Islands 339.80%

An illustrative example of US controlled foreign Company

profits as a percentage of GDP of tax havens:

Organization for

Economic Co-operation

and Development

(OECD)

BEPS Action Plan



OECD – BEPS 2014OECD BEPS Action Plan

“BEPS arises because under the existing rules MNEs are often

able to artificially separate the allocation of their taxable profits

from the jurisdictions in which these profits arise.

This can result in income going untaxed anywhere, and

significantly reduces the corporate income tax paid by MNEs in

the jurisdictions where they operate, thus affecting competition,

distorting investment decisions and reducing overall trust in the

tax system.“

– OECD Webinar



OECD – BEPS 2014OECD BEPS Action Plan – In a nutshell

A group of twenty- ‘G20’ countries realized the need of preventing BESP and

approached OECD to address the issue related to BEPS.

On 19 July 2013 the OECD released an Action Plan on Base Erosion and Profit

Shifting (BEPS) which was presented to the meeting of G20 Finance Ministers in

Moscow.

The purpose of the Action Plan is “to prevent double non-taxation, as well as cases

of no or low taxation associated with practices that artificially segregate taxable

income from activities that generate it.”

The report indicates that “no or low taxation is not per se a cause for concern, but

it becomes so when it is associated with practices that artificially segregate taxable

income from the activities that generate it.”

The Action Plan covers 15 specific Actions which are broadly to be achieved within

a two year time frame (i.e. by the end of 2015). September / October / November

2014, OECD released various recommendations for 9 out of 15 Action Points.

The

coherence

of corporate

tax at the

international

level

Transparency, coupled

with certainty and

predictability

Realignment of

taxation and

substance

15 Actions organized around

three main pillars



OECD – BEPS 2014OECD BEPS Action Plan – An ambitious timeline

Jul 2012 Feb 2013 July 2013 Sept /Oct / Nov 2014

Dec 2015

June 2012

Project announced /

started

February 2013

Release of Document addressing Base

Erosion and Profit Shifting

July 2013

Release of Action plan with 15

separate actions / work streams

September 2014 – Release of

recommendations pertaining to 7

out of 15 Action Points and

Oct/Nov additional 2 Points

December 2015

Completion of

Reminder action plan

2016 onwards

2016 and onwards

Monitoring additional / on

–going compliance

Sept 2015

September / October / November 2014 September 2015 December 2015

Digital Economy Report

Hybrids

Review of HTP Regimes

Preventing Treaty Abuse (including draft on

follow-up work)

Addressing TP aspects of Intangibles

Addressing TP documentation

Multilateral Instrument Report

Addressing avoidance of PE status

Addressing TP aspects of other high risk

transactions (Low Value-Adding Intra-Group

Services)

CFC Rules

Interest Deductibility

Strategy on expansion of FHTP

Addressing TP aspects of Intangibles

Addressing TP aspects of risks and capital

Report on Data and Economic Analyses

Mandatory Disclosure Rules

Dispute Resolution

Addressing TP Interest Deductions

Revision of HTP Criteria

Multilateral Instrument

Action 1:

Addressing the Tax

Challenges of the Digital

Economy



OECD – BEPS 2014Digital Economy – Background

Key features:

Mobility of

business

functions

Reliance on Data

Mobility of Users

Excessive

reliance on

intangible

Multi-sided business

model

Networks effect-

impact of one

user’s decision

on other users

Volatility- low barrier

to entry and fast

growth



OECD – BEPS 2014Digital Economy – Indian scenario

With 200+ million Internet users

Adding 4.5 million every month

India will surpass US and become the second largest user base globally

Five start-ups crossing a billion dollar in value

Currently, 100% FDI in E-commerce is allowed under automatic route in Business to Business (B2B) model and not

B2C model

− Under B2B model, the ecommerce portal Company sells its product to an intermediate buyer who then sells the

product to the final customer, while under B2C model, the ecommerce portal Company sells the product to the

final customer

− Retail trading, in any form, by means of E-commerce is not permissible whether singe Brand / Multi Brand



OECD – BEPS 2014Digital Economy – Indian scenario

Significant challenges in:

The determination of the jurisdiction where value creation occurs

The application of traditional concepts of source and residence

X Co.

(outside India)

Indian Advertisers

Online Advertising Fees

India Co

Marketing

Support

Y Co.

(outside India)

Transfer of IP

Users of free

online

services

Data

Development of algorithms (IP)

for targeted display of

advertising through use of data

Challenges in the digital economy – India Illustration



OECD – BEPS 2014Digital Economy – BEPS recommendations

Way forward:

Task force to continue work on broader challenges including nexus, data and characterization

to ensure that these are addressed effectively

Supplementary report addressing impact of other BEPS initiatives to be released by December

2015

Key tax challenges of the digital economy to be addressed as part of

other OECD/BEPS initiatives including Artificial avoidance of PE

(AAPE), CFC Rules, Transfer Pricing and VAT

Action 7 (AAPE) to consider whether activities hitherto considered as

preparatory or auxiliary activities may result in core activities in digital

economy

Explore possibility of taxation based on concept of “Significant Digital

Presence”

Explore possibility of introducing withholding tax on sale of digital

goods / services



OECD – BEPS 2014Digital Economy – Impact of BEPS recommendations in India

Having regard to the BEPS recommendations, E-commerce business models likely to be subjected to

increased scrutiny in India. Specifically:

• PE assertions by the Tax office based on accessibility of websites from India, presence of equipment,

agents in India, are likely to increase. Also potential tax exposure in India on account of “significant

digital presence” in India

• Value creation through use of customer data generated from India– increased possibility of attribution of

profits to India

• Increased focus on withholding tax implications on e-commerce payments to non-residents

• Possibility of litigation over characterization of payments relating to new digital products and services

(e.g. Cloud computing) as royalties / FTS

Urgent need to evaluate business models and digital presence to assess risks and identify

remedial measures

Action 2:

Neutralising the effects

of hybrid mismatch

arrangements



OECD – BEPS 2014Hybrid Mismatch – Background

Hybrid arrangements – Involve use of cross-border

differences in characterisation of entities and instruments to

produce mismatched tax outcomes

Objective of the BEPS Action plan is to develop model

treaty provisions and design domestic rules to neutralize the

effect of hybrid instruments / entities by not permitting:

• Multiple deductions for a single expense

• Deduction in one country without corresponding

taxation in another

• Generation of multiple foreign tax credits for one

amount of foreign tax paid



OECD – BEPS 2014Hybrid Mismatch – Examples

A Co.

B Co.

Country A

Country BHybrid

Financial

instrument

DEDUCTION IN ONE COUNTRY WITHOUT

TAXATION IN ANOTHER:

B Co issues a hybrid financial instrument to

A Co.

Instrument is characterized as debt in

Country B and as equity in Country A

Country B allows deduction to B Co. for

interest payments made on the instrument

Country A treats the payment as ‘dividend’,

which is entitled to participation exemption

BEPS Recommendations:

Country B to deny deduction to Payer (B Co.)

Defensive rule: Country A to treat receipt as

ordinary income of A Co.

Interest



OECD – BEPS 2014Hybrid Mismatch – Examples ….continued

A Co.

Country A

Country B

B Co.B Co.

B Sub 1

(Operating Sub)

Bank

Interest

Loan

DOUBLE DEDUCTION ON PAYMENTS BY HYBRIDS:

B Co. is a 100% subsidiary of A Co.

B Co. is disregarded for Country A tax purposes

B Co. borrows money and pays interest in Country B

(B Co. derives no other income)

Interest payment are deductible in the hands of A

Co. in Country A, since B Co. is disregarded

B Co. is consolidated with B Sub 1 for tax purposes

in Country B – Interest paid by B Co. claimed as

deduction against operating income of B Sub 1

BEPS Recommendations:

Country A (Parent Jurisdiction) to deny deduction

Defensive rule: Country B (Payer Jurisdiction) to

deny deduction



OECD – BEPS 2014Hybrid Mismatch – Impact of BEPS recommendations in India

BEPS recommendations (once implemented) are likely to impact cross-border arrangements / instruments

where tax characterizations vary in both countries

In an Indian context, such risks may typically revolve around situations where :

• Debt Instruments issued by Indian Cos (e.g. CCDs) may be considered as equity in the debenture

holder’s jurisdiction

• Indian partnerships / LLPs are considered pass-through in overseas jurisdictions

• Dual-resident companies

There is a need to identify arrangements like the above which could be hit under BEPS and to take remedial

measures.

Action 6:

Preventing the granting

of treaty benefits in

inappropriate

circumstances



OECD – BEPS 2014Preventing the granting of treaty benefits in

inappropriate circumstances

Treaty abuse and treaty shopping identified as one of the most important sources of BEPS concerns

Three pronged approach recommended to address treaty abuse and shopping arrangements

Design rules to prevent

granting of treaty

benefits in inappropriate

circumstances

Tax treaties not intended

to be used to generate

double non-taxation

Identification of tax

policy consideration –

required before entering

into a tax treaty

Treaty shopping

“Treaty shopping” generally refers to arrangements through which a person who is not a resident of one of

the two Contracting States that concluded a tax treaty may attempt to obtain benefits that the treaty grants

to residents of these States



OECD – BEPS 2014Treaty Abuse – An Indian perspective

Supreme Court Ruling in Azadi Bachao Andolan on India-Mauritius treaty

LOB - a key component of India’s recent tax treaty negotiations/ re-negotiations (such as treaties signed by India

with UK, Spain and Poland)

LOB meaning:

Subjective arrangement: This is entered into to obtain tax benefits in countries such as Malaysia, Ethiopia,

Estonia and Finland.

Objective treaty: The benefits of this treaty are extended only if the claimant is a qualified person, generally a

government entity, listed company, and so on. It is with countries such as Iceland, Tajikistan, Tanzania and

the US.

Beneficial ownership: This ensures that the benefit of lower withholding tax rate is given to genuine tax

residents of a contracting state. This is with the US, UK, Singapore and Finland.

Substance treaty: Entered into with Singapore, the benefits are given considering the substance of the entity

(not merely a conduit/shell company).

GAAR provisions introduced in Indian Income-tax Act (proposed to be effective from FY 2015-16)

Indian tax office could use BEPS recommendations to deny treaty benefits for inbound investments in India

through mere holding / shell companies.

Urgent need to evaluate investment holding structures and build appropriate commercial rationale for the same.

Action 15:

Developing a multilateral

instrument to modify

bilateral tax treaties



OECD – BEPS 2014Developing a multilateral instrument to modify

bilateral tax treaties

Need to address current bilateral tax treaty system which

facilitates BEPS

• Updation of the current tax treaty network highly

burdensome due to multiple number of bilateral

treaties

Focus on feasibility of use of a multilateral instrument to

implement BEPS measures and modify bilateral tax

treaties

• Multilateral instrument feasible and desirable based

on precedents from various areas other than tax

Recommended to convene an International Conference in

early 2015 to develop the multilateral instrument by OECD

and G20 countries

Action 5: Countering

harmful tax practices

more effectively, taking

into account

transparency and

substance



OECD – BEPS 2014Countering harmful tax practices more effectively,

taking into account transparency and substance

Forum on Harmful Tax Practices (‘FHTP’) to take necessary action to deliver:

• Finalization of review of member country preferential regimes;

• Strategy to expand participation to non-OECD member countries; and

• Consideration of revisions or additions to the existing framework

For review of the existing preferential regimes, emphasis put on:

• Elaborating a methodology to define the substantial activity requirement in the context of IP regimes;

• Improving transparency through compulsory spontaneous exchange on rulings related to preferential

regimes

A progress report provided on the review of regimes of OECD member and associate countries in the

OECD / G20 Project on BEPS

Substantial activity – Adverse impact on IP-holding companies which derive substantial profits on

account of “legal ownership” of the IP

Action 8

Transfer Pricing aspects

of intangibles



OECD – BEPS 2014Definition of ‘Intangible’- within India

Marketing-

Trade mark, Brand names,

logos

Customer-

Customers lists, open purchase

order

Engineering-

Industrial design, trade

secrets

Technology-

Patents, technical Know-

how

Artistic-

Copyrights, Literary work

Intangible

Data processing-

software copyright, automated databases

Contract License agreements , Franchise

agreements , non-compete agreements

Human Capital Trained & Organised work force,

Union Contracts

LocationLeasehold interest, Air rights,

Water rights

Goodwill

Institutional / Professional

Practice / Celebrity goodwill ,

General business going

concern value

Others Methods, Systems, Procedures,

Campaigns, Surveys, Forecasts



OECD – BEPS 2014Transfer Pricing aspects of intangibles

Objective

A broad and clearly delineated definition of intangibles

Ensure that transfer pricing outcomes are in line with 'Value Creation”

Developing TP rules or special measure for transfer of hard to value intangibles

OECD definition of intangible

“something of value which is not a physical asset or a financial asset which is capable of being

owned or controlled for use in commercial activities, and whose use or transfer would be

compensated had it occurred in a transaction between independent parties in comparable

circumstances”

Six Categories of Intangibles defined

including-

Patents know-how and

trade secretsTrademarks Trade name

and Brands

goodwill and

ongoing concern

value



OECD – BEPS 2014Transfer Pricing aspects of intangibles

Guidance issued has certain areas in “interim draft”

To be finalised in 2015 along with other BEPS action points that are closely related (risks and capital,

high-risk transactions and hard to value intangibles

Key areas covered in the Guidance

Detailed guidance on location savings,

assembled workforce and MNE group

synergies as part of Chapter I of OECD

guidelines

Ownership of intangibles and entitlement to

returns – who is entitled to returns from

intangibles

Relevant considerations for various

transactions involving intangibles

Importance of functions, assets and risk analysis in

determining arms length price of transaction involving

intangibles – Development, Enhancement,

maintenance, protection and exploitation

Emphasis on ex-ante return adjustments

Determination of arm’s length price of intangible when

the value is highly uncertain



OECD – BEPS 2014Marketing Intangible and R &D- India perspective

Marketing intangibles

Subject to huge adjustment in India

Application of ‘Bright-line-test’ by Indian Revenue authorities for examining advertising, marketing and

promotional (‘AMP’) activities

Adopting the ‘‘significant people functions’’ approach in determining the economic owner of intangibles

R&D arrangements

Even before the introduction of the BEPS action plan the Indian Revenue authorities issued Circular no. 6

which discusses circumstances in which profit split method will apply for determination of compensation in

case of R&D centers developing intangibles.

Contract R&D

Entities with minimal functions, assets and risk, foreign

entity funds and monitors progress

Circular No. 6

Entrepreneurial R&D Centers

Entities performing significantly

Important functions, assets and risk

Cost plus remuneration is appropriate and

share in profits not necessary

Intangible related return to be attributed to the

Indian researchers under Profit Split Method



OECD – BEPS 2014Action 8 - Intangibles impact in India

What do we expect

Possibility of in-depth scrutiny by the Indian

Revenue authorities on transactions involving

intangibles (location savings, assembled

workforce, group synergies etc) based on OECD

guidelines

What needs to be done : Companies operating in India need to analyze

Legal ownership and contractual

arrangements vis-à-vis intangibles to begin

with

But as next steps more importantly focus

has to be on thorough analysis of

Functions, Assets and Risks (FAR) and

actual conduct of the various entities

1. Who are the parties performing and controlling the functions related to the

development, enhancement, maintenance, protection and exploitation of

intangibles?

2. Who is contributing the assets, including intangibles, physical assets and

funding? Only funding without assumption of other risks entitles to only

return on funding, not the entire intangible related returns

3. Confirm the consistency between conduct of the parties and the legal

arrangements

4. Recharacterise the transactions as necessary to reflect each party’s

contributions towards the intangibles

INDIAN tax authorities are likely to draw inference

and support from OECD guidelines in determining

the return from intangibles-

Recent judgment in case of Mitsubishi Corporation

India Private Limited ITAT relied on OECD guidelines

for loaction savings and assembled workforce.

Action 10

Low value-adding intra-

group services –

Discussion Draft



OECD – BEPS 2014Low value-adding intra-group services – Discussion Draft

Objective

Measures proposed would help reduce the scope

for erosion of tax base through excessive

management fees and head office expenses

Themes for Intervention /

Approach

Identify broad range of intra-group

services, which command a very

limited profit mark-up on costs

Apply a consistent allocation key for

all recipients

Provide greater transparency

through specific reporting

requirements

What constitutes ‘low value-adding intra-group services’

Services that are of supportive nature;

Don’t form part of the core business of Multi National Enterprise Group;

Don’t require the use of unique and valuable intangibles and do not lead to the creation of unique and valuable

intangibles;

Don’t involve the assumption or control of substantial or significant risk and don’t give rise to the creation of

significant risk

Harmonise default waterfall




Activities that would not qualify as a

low value-adding intra-group services

Services constituting the core business

of a MNE group;

Research and development services;

Manufacturing and production services;

Sales, marketing and distribution

activities;

Financial transactions;

Extraction, exploration, or processing of

natural resources;

Insurance and reinsurance;

Services of corporate senior

management.

Activities that would qualify as a low value-adding intra-group services

Accounting and auditing;

Processing and management of accounts receivable and accounts payable;

Human Resources activities such as staffing and recruitment, training and

employee development, remuneration services and developing and monitoring of

staff health procedures, safety and environment relating to employment matters;

Monitoring and compilation of data relating to health, safety, environmental and

other standards regulating the business;

Information technology services where they are not part of the principal activity of

the group;

Internal and external communications and

public relations support (but excluding specific advertising or marketing activities

as well as development of underlying strategies);

Legal services;

Activities with regard to tax obligations;

General services of an administrative or

clerical nature.




Simplified determination of arm’s length charges for low value-adding intra-group services:

Profit Mark-up – MNE service provider shall apply a profit-mark to all costs in the pool. Same mark-up

shall be utilized for all low-value adding intra-group services irrespective of the categories of services.

Prescribed mark-up to be in the range of 2% to 5% of the relevant cost.

Application of benefits test to low value-adding intra-group services:

Tax administration should consider benefits only by categories of services and not on a specific charge

basis

Single annual invoice describing a category of services should suffice to support the charge and

correspondence, or other evidence of individual acts should not be required.



OECD – BEPS 2014India Perspective

From a Captive Shared Service center perspective, certain points such as nature of services outlined as

‘low value-adding’, manner of classifying core and non-core business activities, and proposed mark-up in

the range of 2 per cent to 5 per cent etc may be challenged by tax authorities;

A non-core activity for a Multinational National Corporation (MNC) could be a core activity from a shared

services / back-office perspective and hence appropriate margins would need to determined from a transfer

pricing perspective;

MNCs need to take cognizance while planning the cross charge for services which might be high value /

low value.

Action 13

Transfer Pricing

Documentation and

Country-by-Country

(CbC) reporting



OECD – BEPS 2014Action 13 - TP Documentation and CbC report

Three-tier documentation structure proposed for all countries

Master file to provide the MNE’s blueprint i.e.

• The group’s organizational structure

• A description of the group's business, intangibles, intercompany financial activities, and financial and

tax positions

Local file to provide material transfer pricing positions of the local entity/ taxpayer with its foreign affiliates

• Demonstrates arm’s length nature of transactions

• Contains the comparable analysis.

Country by Country (‘CbC’) Report to provide

• Jurisdiction-wise information on global allocation of income, taxes paid / accrued, the stated capital,

accumulated earnings, number of employees and tangible assets.

• Entity-wise details of main business activities which will portray the value chain of inter-company

transactions.



OECD – BEPS 2014Implementation and India perspective

Implementation:

OECDs endeavor to balance:

• Usefulness of TP documentation under 3-tier structure to tax authorities, and

• Increased compliance cost and efforts for taxpayers

Though consented by OECD member countries and G20 countries, which includes India:

• Mechanism for sharing information with tax administrations yet to be formalized

• Whether Master File and CbC report to be filed by Parent Co. or local entity

• Taxpayers concerns about sharing business sensitive data

• CbC report ought not be used by tax administrations to propose transfer pricing adjustments based on

a global formulary apportionment of income.

Indian Competent Authority commented – India is actively and closely involved in BEPS action plan and

will seek to implement OECDs recommendations on TP documentation



OECD – BEPS 2014Country by Country Reporting template (1/2)



OECD – BEPS 2014Country by Country Reporting template (2/2)



OECD – BEPS 2014BEPS impact in India : Action 13 - Documentation

What do we expect

Adoption of 3 tier documentation structure by The Indian Revenue authorities

Increased compliance cost and burden on taxpayers

Indian Revenue authorities may expect that the Master File and CbC report for all companies operating in India

should be filed locally

As per OECD guidance the Master File and CbC Report should be used only for risk assessment procedures, but

there may be a temptation to use it for allocation of revenue and profits based on functions of various group entities

rather than only looking at Indian entities functions.

What needs to be done

Detailed functional analysis- Companies operating in India especially Indian headquartered companies need to tie

up the functional analysis of Indian operations vis-à-vis global operations as CbC report maps the groups functions

Re-alignment of Transfer pricing global policy- Have Management discussions to re-align functions and pricing to

ensure that profits/income are allocated in accordance with value creation in each jurisdiction

Centralized Details/ Information- Should analyse their internal accounting systems and MIS data, and upgrade the

same to enable gathering of information required in Master File and CbC report

Way Forward



OECD – BEPS 2014Way Forward

Tax and Morality debate: Here to stay

BEPS – Game changer for the Revenue and the Taxpayers

Domestic anti-abuse tax legislations being adopted

globally

Substance and Transparency – part of life

Corporate Tax Rates may be reducing, but the base is

increasing

Companies to not only adhere to compliance regulations but also review their

operating structures in various jurisdictions, as countries are expected to incorporate

the BEPS action points in their local regulations

© 2014 KPMG, an Indian Registered Partnership and a member firm of

the KPMG network of independent member firms affiliated with KPMG

International Cooperative (“KPMG International”), a Swiss entity. All

rights reserved.

The KPMG name, logo and "cutting through complexity" are registered

trademarks or trademarks of KPMG International Cooperative ("KPMG

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BEPS presentation -Final - Copy