International work on BEPS and the related OECD Action Plan have several years of history behind them already. The Tax and Competitiveness Foundation has also been prioritising these developments for a long time now. Likewise, the priority attention that the Fundación Impuestos y Competitividad has given to such developments has already had a long history.
A trail has been left in this website through the publication of papers analysing each of the plan actions and the EU’s anti-abuse directives (from September 2016 to May 2017); and the promotion of and free access to the book “Plan de acción BEPS: una reflexión obligada” (BEPS Action Plan: a necessary reflection) (published in June 2017).
This new contribution from the Foundation’s trustees is consistent with this ongoing attention and is intended as an update so as to (according to the introduction to the document) “reflect on the current status of the BEPS Action Plan measures, describing the activities that have been undertaken to implement and/or transpose the measures into Spain’s positive law, and assessing their impact on the daily activities of the tax function of large multinational enterprises (the main recipients of the measures), on the activities of the tax authorities and on Spanish court rulings”.
This monitoring is necessary. Not in vain, the influence of the BEPS Action Plan has been critical in many tax developments of recent years. It may also be regarded as relevant in view of the Government’s initiative to undertake a possible fiscal reform, including some of the solutions proposed by action 1 and the subsequent developments in the OECD concerning pillars 1 and 2, yet to be completed.
The Foundation is supporting this initiative through its commitment to research and study international tax developments and, of course, the way in which they are reflected in Spanish tax legislation. This document is to be supplemented by means of webinars for discussion and reflection, organised with the invaluable assistance of the Institute for Fiscal Studies.