德勤全球-2019_BEPS_global_survey_55页_6mb

OECD's BEPS Initiative and the "Global Tax Reset" – Summary of Deloitte's 2019 Multinational Survey

Core Content

Deloitte's 2019 multinational survey, part of the OECD's Base Erosion and Profit Shifting (BEPS) initiative, provides insights into how multinational corporations (MNCs) are responding to evolving global tax regulations and increased scrutiny. The survey collected responses from 405 individuals across 35 countries, highlighting the impact of BEPS and related tax reforms on MNCs' strategies, operations, and internal processes.

Main Points

• Media, Political and Activist Interest in Tax: 74% of respondents believe their organization is concerned about the heightened interest in corporate taxation by media, political entities, and activist groups.
• C-Suite and Board Engagement: 76% of respondents agree that their C-suite and/or Board are actively involved in tax strategy and risk monitoring, with a slight decrease from 2018.
• Changes in Tax Planning: 41% of respondents report that their organization has changed its approach to cross-border tax planning due to BEPS-related legislative changes.
• Cross-Border Structure Changes: 38% of respondents state their organization has implemented significant changes to cross-border structures as a result of BEPS.
• Restructuring of Financing Arrangements: 37% of respondents believe their organization is restructuring financing due to Action 4 (Interest deductibility).
• M&A Tax Due Diligence: 23% of respondents have re-focused M&A tax due diligence to address BEPS-related risks.
• Resource Allocation for Tax: 38% of respondents have secured or plan to secure additional resources for tax functions due to BEPS.
• Tax Authority Examination Rigor: 54% of respondents believe tax authorities are becoming more rigorous in examinations.
• Scrutiny of Low Tax Countries: 58% of respondents agree that tax authorities are applying greater scrutiny to operations in low tax countries.
• Use of Data Tools by Tax Authorities: 66% of respondents agree that tax authorities are increasing their use of data gathering and analytics tools.
• Legislative and Treaty Changes: 62% of respondents believe their country has seen significant legislative and treaty changes related to BEPS.
• Unilateral Legislative Changes: 61% of respondents agree that unilateral changes to protect the tax base are occurring without international coordination.
• Lack of Guidance from Tax Authorities: 45% of respondents express concern about the lack of guidance on BEPS-related changes.
• Unilateral Tax Rulings: 30% of respondents report obtaining fewer unilateral tax rulings due to the changing tax landscape.
• Bilateral Advance Pricing Agreements (APAs): 22% of respondents indicate they are obtaining more bilateral APAs as a response to BEPS.

Key Findings

• Global Trends: The level of concern and engagement with BEPS-related issues remains high, though some areas show a leveling off or decline.
• Country Variations: Responses vary significantly by country, with some jurisdictions like the US, India, and Singapore showing increased concerns or actions, while others such as China, the UK, and Germany show reductions.
• Industry Differences: Financial services and technology, media, and telecommunications industries are more affected by BEPS-related changes, with manufacturing & engineering showing lower impact.
• Technological Impact: There is an increasing use of technology and data analytics by tax authorities, which is reflected in the responses of MNCs.
• Political and Media Influence: The survey highlights that media and political interest in tax matters is a growing concern for MNCs, with tax strategy now often integrated into broader corporate responsibility agendas.

Conclusion

The survey underscores the ongoing impact of the BEPS initiative on MNCs' operations, strategies, and internal processes. While many organizations have adapted by implementing new policies, restructuring financing, and enhancing due diligence, the pace and extent of these changes vary across regions and industries. The growing use of technology and data analytics by tax authorities is a key trend, and there is a notable shift in how tax strategy is viewed as part of corporate responsibility rather than just compliance.