Understanding and Implementing OECD’s BEPS Framework for Global Tax Compliance

Introduction

Base Erosion and Profit Shifting (BEPS) refers to corporate tax planning strategies that exploit gaps and mismatches in tax laws to artificially shift profits to low-tax jurisdictions. To counter aggressive tax avoidance, the OECD developed the 15 BEPS Action Plan, which enforces global tax transparency, transfer pricing regulations, and corporate tax governance.

This 5-day intensive training course provides an in-depth understanding of OECD’s BEPS framework, compliance measures, and corporate tax risk mitigation strategies. Participants will learn how to implement BEPS-compliant policies, ensure tax transparency, and manage cross-border tax obligations.

Course Objectives

By the end of this course, participants will be able to:

• Understand BEPS risks and anti-tax avoidance strategies.
• Navigate OECD’s 15 BEPS Action Plan and its impact on multinational taxation.
• Implement Country-by-Country Reporting (CbCR) and transfer pricing documentation.
• Ensure compliance with OECD Multilateral Instrument (MLI) and tax treaty modifications.
• Develop corporate tax governance strategies to prevent BEPS-related risks.

Who Should Attend?

This course is ideal for:

• Corporate tax professionals and finance executives
• Tax consultants, CPAs, and auditors
• Government tax regulators and policymakers
• Legal and compliance professionals handling cross-border taxation
• Multinational business owners and financial controllers

Prior knowledge of corporate taxation is beneficial but not required.

Course Outline

Day 1: Introduction to BEPS and Global Tax Avoidance

• Understanding Base Erosion and Profit Shifting (BEPS)
• Why BEPS is a threat to global tax fairness and economic stability
• Overview of the OECD’s 15 BEPS Actions
• The impact of BEPS on multinational tax structures and digital taxation
• Key regulatory frameworks: OECD, G20, EU Anti-Tax Avoidance Directive (ATAD)

Workshop: Analyzing real-world BEPS cases and their economic impact

Day 2: OECD’s 15 BEPS Action Plan & Compliance Strategies

• Action 1: Addressing the Tax Challenges of the Digital Economy
• Action 2: Neutralizing Hybrid Mismatch Arrangements
• Action 3: Strengthening Controlled Foreign Company (CFC) Rules
• Action 4: Limiting Base Erosion via Interest Deductions
• Action 5: Countering Harmful Tax Practices (Tax Havens & IP Regimes)

Case Study: How digital multinational corporations adjust to BEPS digital tax policies

Day 3: Transfer Pricing & Transparency Measures (BEPS Actions 6-10)

• Action 6: Preventing Treaty Abuse & Tax Treaty Shopping
• Action 7: Preventing Artificial Avoidance of Permanent Establishment (PE) Status
• Action 8-10: Ensuring Transfer Pricing Outcomes Align with Value Creation
• Role of the OECD Transfer Pricing Guidelines in BEPS compliance
• How BEPS strengthens enforcement against abusive intercompany pricing

Workshop: Identifying transfer pricing risks in a multinational’s tax structure

Day 4: Country-by-Country Reporting (CbCR) & Corporate Tax Governance (BEPS Actions 11-15)

• Action 11: Measuring and Monitoring BEPS Risks
• Action 12: Mandatory Disclosure Rules (MDR) and Tax Transparency
• Action 13: Country-by-Country Reporting (CbCR) Implementation
• Action 14: Dispute Resolution Mechanisms for Tax Controversies
• Action 15: OECD Multilateral Instrument (MLI) and Global Tax Treaty Modifications

Case Study: Developing a BEPS-compliant tax reporting framework for a multinational enterprise

Day 5: The Future of BEPS Compliance & Global Minimum Tax

• OECD’s Two-Pillar Solution (Pillar 1 & Pillar 2) and Global Minimum Tax (15%)
• The rise of real-time tax reporting and digital tax compliance
• AI and big data analytics in BEPS risk detection
• How to develop a BEPS risk management strategy for multinational corporations
• Future trends in international tax transparency and anti-avoidance policies

Capstone Exercise: Designing a corporate tax governance strategy for BEPS compliance

Conclusion & Certification

Participants who complete the course will receive a Certification in BEPS Compliance & International Tax Governance, demonstrating expertise in OECD’s BEPS framework, tax transparency, and corporate tax risk mitigation.

Program Benefits

• Comprehensive Coverage – Covers all 15 BEPS Actions, MLI, and CbCR compliance.
• Hands-On Learning – Includes case studies, tax planning workshops, and compliance frameworks.
• Regulatory Compliance Confidence – Ensure alignment with OECD, G20, and EU tax laws.
• Risk Mitigation Focus – Learn strategies to reduce tax controversy risks and avoid BEPS penalties.
• Future-Proof Knowledge – Stay updated on emerging BEPS policies and AI-driven tax enforcement.