Select the Action Plan below to access information.
We will be updating this page with more content regularly.

Introduction to BEPS

“BEPS has already resulted in behavioral change in some form or fashion; everyone is (or should be) sensitive to BEPS, it adds another layer of rules and regulations that need to be considered. ”

Shannon Stafford
Managing Director, Tax,
The Carlyle Group

Action Plan 2: Neutralising the Effect of Hybrid Mismatch Arrangements

“Anyone operating cross-border should review their structures. The anti-hybrid rules have the potential to catch reasonably common arrangements.”

Matthew Saronson,
Tax Partner,
Debevoise & Plimpton LLP

Action Plan 4: Limiting Base Erosion Involving Interest Deductions and Other Financial Payments

“Sustainable and responsible financing structures have always been important to us. With the new BEPS driven changes, we are paying particular attention to detailed stress testing of financial modelling scenarios to ensure the limitations on tax deductions do not hinder free cash flow for business operation and/or strategic growth plans. Clearly some industries are impacted more than others, driven by their relative natural appetite for leverage, and we are addressing each on a bespoke basis for that business need. The analysis is complex, especially for businesses generating EBITDA internationally, and particular care needs to be taken on a case by case basis.”

Alexandra Hone
Global Head of Tax,
Intermediate Capital Group Plc.

Action Plan 6: Treaty Abuse

“Substance is at the heart of the BEPS project and this is clearly evidenced in Action 6. The rules will apply to existing structures, therefore any group that relies on a holding company obtaining treaty benefits needs to determine whether they need to take action to protect against losing future treaty benefits.”

Richard Ward,
Tax Partner,
Debevoise & Plimpton LLP

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Debevoise has experienced tax professionals in the USA, UK, France and Hong Kong. The resources below consider how BEPS is being implemented and provide detail about some of the issues that are arising as part of this implementation process.

DebevoiseWhat You Need to Know About Structuring Your Fund in the BEPS Era
DebevoiseTax Treaty History – the Action 15 Multilateral Instrument
DebevoiseAsk an expert – The anti-hybrids rules and private equity fund structures
DebevoiseLMA Concerns: Hybrid Mismatch Rules (Action 2) and Interest Deductibility Rules (Action 4)
DebevoiseAnalysis - BEPS Action 6 and Private Equity Funds
DebevoiseState Aid and BEPS
Debevoise BEPS in France
Debevoise Diverted Profits Tax & BEPS
Debevoise BEPS Primer: Key Definitions
Debevoise 10 Things You Should Know About BEPS
Debevoise Brexit and BEPS
DebevoiseBEPS Implementation Tracker

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Latest News

We have selected below some of the most interesting and current reports
about BEPS from external news sources, allowing you to keep up to date easily.

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Something piqued your interest? Get in contact, we’d be very happy to help.

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