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BEPS Action Plan: A Case Study of the Potential Implications for a U.S.-Based Multinational

Mar 17, 2014
From the KPMG TaxWatch

By Jim Carr, Jason Hoerner, Violetta Sorokina, and Sue Yueqian Wu, KPMG LLP

March 17, 2014 | In this article, the authors consider the potential impact of the OECD's Base Erosion and Profit Shifting (BEPS) action item proposals on U.S. multinational enterprises (MNEs) with deferral structures, such as those commonly based in Ireland or the Netherlands.

Using a current Irish deferral structure as a case study, this article describes how this structure may be affected by the potential changes under the BEPS action plan. Also outlined are steps that MNEs may wish to consider to counter the impact of the BEPS proposals should they become law.

This article was published in the March 17, 2014, issue of Tax Notes International and appears here with the permission of Tax Analysts.

Read BEPS Action Plan: A Case Study of the Potential Implications for a U.S.-Based Multinational