The OECD’s Base Erosion and Profit Shifting (BEPS) project has been an ambitious and near-unprecedented undertaking to examine the coherence, substance, and transparency of the international tax system. Since the project was initiated, the OECD has sought stakeholder consultation to garner support for a consensus-based series of recommendations to accomplish a consistent and coordinated implementation of the ultimate reform package proposed.
In this Tax Insight we examine the unilateral legislative actions taken by the UK — via the Diverted Profits Tax (DPT) — and Australia — via the Multinational Anti-avoidance Law (MAAL) — to immediately address perceived avoidance behaviors of prominent concern. In both instances, these countries have promulgated targeted anti-avoidance/anti-abuse rules to thwart opportunities for the ongoing erosion of their domestic tax bases, particularly through the avoidance of permanent establishment (PE) status resulting from what are perceived to be contrived or abusive structures.
Source & more info: PwC