The BEPS Action Plan emphasizes the importance of substance over form in corporate structures and transactions. Gate4Business offers expert tax advisory services to help clients ensure that their business structures reflect actual economic activities, rather than merely designed to shift profits artificially.
We work with clients to implement tax-efficient structures that comply with the OECD’s recommendations while maximizing tax benefits. This includes advice on transfer pricing, intercompany financing, and profit allocation based on actual business activities.
One of the core pillars of the BEPS Action Plan is ensuring that intercompany transactions are priced according to arm’s length principles. Gate4Business provides detailed guidance on transfer pricing compliance, helping clients develop proper documentation and policies for pricing intercompany transactions to reflect the value created in each jurisdiction.
We ensure that businesses can justify their transfer pricing arrangements to local tax authorities, reducing the risk of audits and penalties under Action 8-10 of the BEPS plan, which addresses the taxation of intangible assets and other business operations.
Under the BEPS guidelines, tax authorities are increasingly scrutinizing whether a company has real substance in the jurisdictions where it claims to be operating. This means that companies need to ensure they have genuine operations, employees, and assets in the countries where they are claiming tax residence.
Gate4Business assists clients in aligning their corporate structures with the BEPS requirement for substance over form. This includes advising on local presence, ensuring that companies engage in meaningful business activities, and facilitating the setup of operational offices and hiring staff in relevant jurisdictions.
Multinational companies often have complex corporate structures that may no longer be tax-efficient under the new BEPS rules. Gate4Business conducts thorough reviews of existing international structures to identify potential risks or mismatches between the location of profits and where value is actually created.
We assist in restructuring operations, ensuring that business activities are properly aligned with tax jurisdictions to minimize exposure to potential audits or adjustments. This may include establishing new entities in jurisdictions that have robust BEPS-compliant frameworks or revising intercompany agreements to reflect actual economic activities.
BEPS Action 6 focuses on preventing the misuse of tax treaties, particularly through treaty shopping. Gate4Business helps clients navigate the complexities of international tax treaties, ensuring that they are not subject to double taxation or exposed to risks from improperly structured cross-border transactions.
We offer solutions to ensure compliance with the Principal Purpose Test (PPT), a key tool in BEPS Action 6 that limits the use of treaties when the principal purpose is to gain a tax advantage without any substantial business purpose.
Under Action 13 of the BEPS plan, multinational enterprises are required to provide Country-by-Country Reporting (CbCR), which discloses how much income, tax, and economic activity a company generates in each jurisdiction. This increases transparency and allows tax authorities to detect and address BEPS-related risks.
Gate4Business assists clients in preparing and filing their CbCR reports, ensuring full compliance with local laws. We also provide guidance on how to structure their operations to minimize potential red flags and enhance transparency.
To mitigate BEPS risks, businesses must stay on top of their local tax compliance. This involves ensuring that all tax filings are accurate, timely, and reflect the true economic activity of the business. Gate4Business provides full tax compliance services, from annual corporate tax returns to value-added tax (VAT) filings, ensuring that clients meet their local obligations while reducing exposure to BEPS-related penalties.
Gate4Business helps clients strengthen their corporate governance frameworks, ensuring that their management structures align with BEPS principles. We offer risk management strategies that help companies protect themselves from tax disputes, penalties, and reputational damage resulting from BEPS-related issues.
With BEPS influencing international tax rules, companies must take a strategic approach to global tax planning. Gate4Business works with clients to develop tax strategies that comply with BEPS guidelines while optimizing tax outcomes across jurisdictions. We help clients identify opportunities for tax-efficient financing, cross-border structuring, and asset protection.
As BEPS continues to reshape international tax rules, businesses must adopt strategies to mitigate its potential consequences. Gate4Business is committed to helping businesses navigate these changes by providing expert tax advisory, compliance services, and operational solutions. We work closely with our clients to ensure their corporate structures and tax strategies are fully aligned with the BEPS Action Plan, reducing risk and optimizing tax efficiency.
Contact Gate4Business today to learn more about how we can help your business mitigate the impact of BEPS and ensure compliance with global tax regulations.