Tax World: The Post BEPS World

Learning CentreTax World: The Post BEPS World

Tax World: The Post BEPS World

Recently, tax authorities have been paying more attention to commodity traders.

In light of the digital economy, some jurisdictions have introduced diverted profits tax or anti-avoidance measures to counter these types of structures. These measures could impact commodity traders as they are also a potentially good vehicle for arranging a tax-efficient structure, and for some tax jurisdictions, they will be viewed as a more sophisticated means of arranging the same type of arrangements.

As a result of these changes, tax authorities now have more information, enabling revised transfer pricing guidelines to be agreed upon in consultation with the taxation authorities of the countries concerned. The BEPS proposals should assist tax authorities in ascertaining the total profit relating to the supply chain (though a combination of CbC reporting and the exchange of information between tax authorities) and how it could be allocated to the different functions and thus jurisdictions that make up the value chain (via revised transfer pricing guidelines).