Nov 201511:00 BST

Understanding OECD's BEPS Project

Understanding OECD's BEPS Project
Find out more about the OECD’s initiative to tackle Base Erosion and Profit Shifting (BEPS).

Questions included:

  • How are different countries approaching BEPS? The UK, for instance, is quite a long way down the road in its thinking. At what stage in the process are other countries? What will the US do?
  • Germany has already strict comprehensive transfer pricing regulations. Nevertheless, there is a need for some adjustments of the regulations in Germany in order to comply with the recommendations of the OECD. What will Germany do?
  • One of the biggest impacts will be change to the model treaty. In the US, companies are used to dealing with “Limitation on Benefits” clauses. How will the world's tax authorities and non-US global companies deal with the headache-inducing LOB clause?
  • What’s the new guidance on intangibles and what might this mean for traditional offshore IP structures?
  • And lots more!

Our panelists were:

  • Stephen Alleway, Transfer Pricing Partner, Questro International, Switzerland
  • Benedetto de Francesco, Chartered Accountant and Legal Auditor, Italy
  • Michael Heckel, Heckel Consulting, Germany
  • Divya Ramaswamy, Senior Solutions Consultant, Thomson Reuters, UK
  • Heather Self, Partner (Non Lawyer), Pinsent Masons, UK
  • Ted Brooks, Lawyer, BrooksLaw PC, USA

On October 8th, the OECD released the final package of their Base Erosion & Profit Shifting (BEPS) project and sent it to the G20 Finance Ministers.

Upon its release, OECD Secretary-General Angel Gurría said, “Base erosion and profit shifting is sapping our economies of the resources needed to jump-start growth, tackle the effects of the global economic crisis and create better opportunities for all.”

15 specific Actions were set forth by the study in a widespread effort to curtail tax avoidance.

Audio Recording & Transcript

Please feel free to download the full transcript below.


Here's the full audio recording.

Submit Your Questions

If you've listened to the recording or read the transcript and have any follow-up questions for our panel, please feel free to submit them on our forum discussion.


Our Panellists

Stephen Alleway is a transfer pricing partner with Questro International in Zurich, Switzerland Stephen Alleway is a transfer pricing partner with Questro International in Zurich, Switzerland. Before co-founding Questro International, Stephen was a partner with a Big 4 firm where he was TP Leader for Switzerland. He has acquired broad experience in leading large global projects for Swiss and foreign headquartered multinationals. Stephen has worked in the UK, Australia, and Switzerland, and has gained experience across a range of industries and other tax jurisdictions. Stephen has advised on transfer pricing for the past 17 years and has been named as a leading transfer pricing adviser in various publications. Contemporaries cite him as an adviser recommended for his transfer pricing work in the Swiss market. He is a contributor to publications on transfer pricing and speaks widely on the subject in Switzerland and at international conferences. Stephen is also a director of Otico Software, which develops time saving tax solutions. In this regard, Stephen has recently been working on applying IT in in response to the OECD BEPS challenges.

Benedetto de Francesco is a Chartered Accountant and Legal Auditor based out of Rome, Italy

Benedetto de Francesco is a Chartered Accountant and Legal Auditor based out of Rome, Italy. He has been Partner at De Francesco & Partners - Studio Commerciale Legale Tributario for the past ten years, offering services in: auditing (accounting and tax compliance), finance, tax litigation, anti-money laundering compliance, mergers & acquisitions, due diligence procedures, debt restructuring, financial recovery, credit risk assessment, financial architectures, EVA driven strategies, successions, and family asset management.

Michael Heckel of Heckel Consulting in Munich, Germany Michael Heckel of Heckel Consulting in Munich, Germany, has more than 14 years experience in transfer pricing. He worked for several years with one of the big global operating audit, tax and advisory firms as General Manager. Before he started his own business with in 2014, he  worked with a medium-sized consulting firm as Director of the transfer pricing department. He is connected with an international and national network of experts in transfer pricing and other related topics.

Divya Ramaswamy is Senior Solutions Consultant for Thomson Reuters in London, UK. Divya Ramaswamy is Senior Solutions Consultant for Thomson Reuters in London, UK. She focuses on ONESOURCE Transfer Pricing technology. She has over 10 years of transfer pricing, tax, and accounting experience. Prior to joining Thomson Reuters, she  worked with tax consulting firms. In her current role, she uses her subject matter expertise to help match technology to client needs.

Heather Self is a Partner (Non Lawyer) at Pinsent Masons Heather Self is a Partner (Non Lawyer) at Pinsent Masons with almost 30 years of experience in tax. She has been Group Tax Director at Scottish Power, where she advised on numerous corporate transactions, including the $5bn disposal of the regulated US energy business.  She also worked at HMRC on complex disputes with FTSE 100 companies, and was a specialist adviser to the utilities sector, where she was involved in policy issues on energy generation and renewables. She is a member of the CBI Tax Committee and a former Chairman of the CIOT Technical committee. While at HMRC, she was a member of the joint working group on the development of the new Controlled Foreign Companies (CFC) regime.

Our Moderator

Ted Brooks, a lawyer with BrooksLaw PC in Washington, DC, USA. Our moderator was Ted Brooks, a lawyer with BrooksLaw PC in Washington, DC, USA.

Mr. Brooks has over 20 years of public company, private company and law firm experience developing strategic tax planning initiatives for businesses and investors, including international corporate treasury centers, intellectual property development structures, hedge funds, asset management vehicles, joint ventures, structured financings and complex M&A transactions. He specializes in both U.S. and non-U.S. tax laws and is a frequent speaker on U.S., international and cross-border taxation.
In 2011, Mr. Brooks successfully launched the U.S. affiliate office of Weidema van Tol, Attorneys & Tax Advisors, an international law firm with offices in Luxembourg, Switzerland, the Netherlands & Washington DC. Previously, Mr. Brooks was Vice President of Tax and General Tax Counsel for ContourGlobal, a company that develops, acquires and operates conventional and renewable power and energy companies around the globe. Ted was formerly Vice President, International Tax and Global Tax Counsel for Marriott International, a leading hospitality and lodging company with more than 3,000 properties in the U.S. and 67 other countries and territories around the world. Mr. Brooks is a member of the District of Columbia Bar and is admitted to practice before the U.S. Tax Court. He is a member of the D.C. Bar Tax Section, the American Bar Association and the ABA Tax Section.
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