What the participants learned

This learning event aimed to provide participants with a broad knowledge of the issues to anticipate when auditing multinational enterprises. It included discussions of the most significant legal and practical issues to be taken into account, beginning with the creation and legal significance of a multinational enterprise (MNE), the tax principles underlying the operation of an MNE, tax avoidance and anti-avoidance strategies, the operation of tax treaties, and an introduction to transfer pricing and thin capitalization issues. Furthermore, the “best practice” audit approaches that are adopted to deal with these entities by OECD countries as well as countries participating in the seminar have been examined. Audit examples were included as far as possible to encourage debate and provide a practical basis for the examination of these issues in the work place. The seminar also dealt with the relevant administrative provisions, information requirements and the audit process itself in order to facilitate the work of tax examiners who may have had only limited expertise.

This event has been created by the OECD to provide tax administrators and policymakers in developing countries with a practical and interactive way to:

• identify BEPS practices
• assess BEPS risks and
• apply BEPS solutions, discussing the tools available both at the international and domestic legislation levels.

The ultimate objective of this event was for participants to better understand aggressive tax planning and advise the relevant authorities on the implementation of BEPS solutions at the legislative, regulatory and administrative levels.

The workshop was based on a week long case study, complemented with technical lectures, where participants have been confronted with a fictitious case study. The event was highly interactive and relied on the analysis of the facts and circumstances by participants. Discussions in break-out sessions and in the plenary helped understand planning structures and arrangements, and compared the usefulness and relevance to the respective countries of BEPS solutions.

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Who attended

Tax administrators and tax inspectors responsible for or engaged in the audit of multinational enterprises. Also, Ministry of Finance staff involved in implementing BEPS outcomes.

Partners

This learning initiative was supported by: