BEPS Action 4: Policy Considerations and Implementation Status

This article addresses BEPS Action 4. The authors provide a historical perspective of the relevant BEPS and EU measures, explain the highlights of BEPS Action 4, discuss the overlap between the different Actions, update readers on countryspecific implementation of BEPS Action 4, summarize existing case law in the area, present practical examples dealing with the impact of Action 4 on certain structures and, finally, provide concluding remarks.

Authors: René Offermanns (IBFD) - Steef Huibregtse, Louan Verdoner and Avisha Sood, TPA Global (Amsterdam)

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