2015年-德勤全球_2018_BEPS_global_survey_47页_2mb

Summary of Deloitte's 2018 OECD BEPS Multinational Survey

Core Content

Deloitte conducted its fifth annual multinational survey in 2018 to assess the impact of the OECD's Base Erosion and Profit Shifting (BEPS) initiative and the "Global Tax Reset" on multinational companies. The survey collected responses from 447 participants across 39 countries, providing insights into how organizations are adapting to the evolving tax landscape.

Main Findings

Overall Trends

• 76% of respondents believe their organization is concerned about the increased media, political, and activist group interest in corporate taxation.
• 76% of respondents agree or strongly agree that the C-suite and/or Board of Directors are actively engaged in tax strategy and risk assessment.
• 62% believe tax planning has become a corporate responsibility issue, not just compliance.
• 85% expect significant unilateral legislative changes to protect the tax base, not coordinated with other countries.
• 78% believe double taxation will occur due to unilateral tax law changes.
• 69% expect double taxation even without unilateral changes.
• 91% agree that the corporate tax compliance burden will increase due to transfer pricing reporting requirements.
• 69% believe the compliance burden will increase due to more foreign permanent establishments.
• 32% have secured or plan to secure additional resources for their tax group due to BEPS-related changes.
• 30% anticipate significant legislative and treaty changes in their country.
• 34% believe their organization has re-focused M&A tax due diligence on BEPS risks.
• 32% agree that their organization has changed cross-border tax planning due to BEPS.
• 31% believe their organization has implemented significant changes to cross-border structures.
• 37% expect higher withholding tax obligations due to treaty changes.
• 21% believe tax authorities will interpret transfer pricing guidelines consistently.

Country-Specific Insights

• United States had the highest number of respondents (157), followed by the United Kingdom (56), Netherlands (23), Switzerland (22), and Australia (21).
• Tax Directors/Tax VPs (248) were the most represented role, followed by International Tax Directors (67), International Tax Managers (58), and Controllers/CFOs (31).
• Financial services and energy and resources industries showed the highest levels of concern and activity in response to BEPS.
• CFOs/Controllers were less likely to agree with significant changes in tax planning and compliance than Tax Directors/Tax VPs.

Key Views on BEPS Impact

• Increased Scrutiny: Most organizations believe that tax structures are under greater scrutiny, and tax authorities will increase audit assessments globally.
• Compliance Burden: A significant portion of respondents expect a substantial increase in compliance burden due to BEPS-related reporting and PE requirements.
• Strategic Re-evaluation: Many organizations have re-focused their tax strategies and due diligence processes, particularly in response to BEPS and State Aid cases.
• Unilateral Changes: There is widespread concern about the potential for unilateral legislative changes, which could lead to double taxation and reduced coordination across countries.

Critical Observations

• The level of concern about media and political interest in corporate taxation has remained consistent, with minor variations across countries.
• Tax planning is increasingly seen as a strategic and corporate responsibility issue rather than a purely compliance matter.
• While some countries (e.g., the UK, France, Canada) have shown increased concern, others (e.g., Switzerland, Denmark) have seen a decline.
• The Multilateral Instrument (MLI) and country-by-country reporting have significantly impacted compliance expectations and resource allocation.
• State Aid cases by the European Commission are influencing tax structure implementation, with a notable increase in China's responses.

Conclusion

The 2018 survey highlights that the BEPS initiative has had a substantial impact on multinational corporations, prompting changes in tax strategy, compliance, and resource allocation. Despite the complexity and uncertainty surrounding BEPS implementation, organizations are adapting to the new tax environment, with increased engagement from C-suite and tax leadership. However, there is still a significant portion of companies that have not yet implemented major changes, indicating ongoing challenges and the need for further adaptation.