1. MULTILATERALISM, COORDINATED BI-UNILATERALISM OR CHAOS
María Teresa Soler
MULTILATERALISM, COORDINATED BI-UNILATERALISM OR CHAOS
Consistency and Hierarchy among the BEPS Actions

2. THE CONCEPT What BEPS Action Plan is really about
María Teresa Soler Roch
THE CONCEPT
What BEPS Action Plan is really about
Tackling base erosion and profit shifting
Why: “agressive” tax planning / tax competition
Which (tax base)
Where (profit shifting)
The Action Plan
Two different approaches

3. THE TARGETS TAX AVOIDANCE TAX COMPETITION
Treaty shopping. PPT necesary? Rule shopping?
Artificial avoidance of PE. A better approach?
TAX COMPETITION
BEPS and tax incentives
Preferential tax regimes (focused on PB)

4. THE TARGETS DOUBLE NON TAXATION FAIR SHARE (MNEs)
(Legal) A new goal. Specific provisions?
(Economic) Hybrids and other limitations
Collateral dammages?
FAIR SHARE (MNEs)
Effectiveness of the Action Plan as a whole
Relevant issues out of the scope of the BEPS project

5. THE LANDMARKS ECONOMIC SUBSTANCE and VALUE CREATION TRANSPARENCY
TP issues more relevant
Actions 3 and 5. Mismatches?
TRANSPARENCY
CbC reports more relevant
Strategy disclosure. Future risks?

6. IMPLEMENTATION EFFECTIVENESS Overall approach
María Teresa Soler
IMPLEMENTATION
EFFECTIVENESS
Overall approach
Different scenarios
Different legal instruments
Dispute resolution. Still too far from a TSDS system
Digital economy. What to do?

7. IMPLEMENTATION DIFFERENT LEVELS Multilateralism . A work in progress
Bilateral. Impact on the TT network
Unilateral (DPT and the like)
Supranational (EU)
Risk of chaos?
Last but not least: Court decisions