Increasing controversy for offshore structures after BEPS

Global Transfer Pricing

TPA Global is initiating a series of webinars covering the global impact of the emerging BEPS developments on offshore structures. In the first webinar of this series, we will analyze the impact of applicable BEPS Action points on offshore structures from a global/OECD perspective and present some live cases impacted by these Action points and will end with recommendations to companies in similar situations.

Key Highlights of the webinar:

  • Presentation of the following elements of BEPS dealing with offshore structures:
    • Action 3 – CFC rules
    • Action 5 – Harmful tax practices
    • Action 6 – Principal Purpose Test/ Limitation of Benefits
    • Actions 8 – 10 – Allocation of risks and intangibles in line with significant people functions
  • Presentation of the impact of BEPS Action points on offshore structures through three current running cases of family owned businesses:
    • Singapore Procurement Office
    • Hong Kong product development office
    • Taiwanese production office under Hong Kong holding in combination with Dutch innovation box

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