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KPMG report: Update on future of BEPS guidance from OECD

Noel Maher, Tax Policy Adviser from the OECD, discussed ongoing work at the OECD at KPMG-sponsored conference

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December 4, 2024

Noel Maher, Tax Policy Adviser from the Organisation for Economic Cooperation and Development (OECD), speaking today at the KPMG-sponsored TP Minds West Coast conference, discussed the ongoing work at the OECD and possible focus areas for 2025.

With respect to the current status of Amount B (also known as the simplified and streamlined approach), Maher confirmed that the OECD has been working closely with the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) since publication of the Amount B report in February, to survey members, conduct technical training programs, and produce further tools and guidance to support implementation. Maher indicated that the OECD would soon publish its next update, which would include the release of a newly developed pricing automation tool that will allow both taxpayers and tax administrations to quickly and reliably compute Amount B returns for in-scope entities.

Maher also confirmed that wider Pillar One discussions are ongoing as the Inclusive Framework seeks to agree a final package. 

Moving beyond Amount B and the two-pillar solution, Maher suggested that the OECD and Inclusive Framework members had been taking steps this year to reflect on the progress made to tackle BEPS over the last 10 years and that this period of reflection would continue in 2025 to help inform a future program of work for 2025 and beyond.

Looking to 2025, Maher said that he was excited by the prospect of continuing initial work done by several working parties exploring the tax challenges arising from the global mobility of workers which have emerged since COVID-19. The interpretation and application of existing tax treaties and transfer pricing guidelines to “new-normal” fact patterns involving cross-border teleworking, globally dispersed contributions to risk control and intangibles, and the relocation of senior employees have been identified by business stakeholders as some of the key areas requiring further clarification and guidance.  

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