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By Emilien LEBAS, Associate Partner, KPMG Luxembourg
The last years have been characterized by an impressive and global trend for increasing tax transparency led, in particular, by the Organisation for Economic Co-operation and Development (OECD). In this context, the OECD Project against base erosion and profit shifting (BEPS) sets out 15 key actions to reform the international tax framework and ensure that profits are reported where economic activities are carried out and value created.
Given the number of tax treaties in force between the countries willing to implement OECD’s anti-BEPS recommendations, implementing the recommendations of the BEPS Project on a treaty-by-treaty basis would be a lengthy process, requiring more than 3,000 sets of...
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