International Tax Cooperation: UK Sets Out Its Priorities for the OECD Base Erosion and Profit Shifting (BEPS) Project

Sullivan & Cromwell LLP - 9 April 2014

The UK government has published a paper setting out in detail its position on the OECD’s Action Plan on Base Erosion and Profit Shifting.

Distinct from the general discussion surrounding the wide-reaching aims of the BEPS project, the 19 March paper gives helpful detail on the main points of interest from a UK perspective.

The UK’s approach can be summarised as follows:

  • support for the BEPS project in general;
  • support for many of the Action Plan’s specific proposals;
  • a belief that the UK offers models for what can be done in several areas, coupled in some cases with a reluctance to go beyond what the UK has already done;
  • concern that measures to counteract BEPS should be proportionate, bearing in mind:
    • the sovereignty of taxing jurisdictions; and
    • the potential costs to government and business of some proposals; and
  • sensitivity as to the impact on the UK’s financial sector and investment in UK infrastructure.