Base erosion and profit shifting (BEPS) refers to tax-planning outcomes that exploit gaps or mismatches in tax rules so that profits are shifted away from the jurisdictions where the underlying economic activity and value creation occur. The OECD/G20 BEPS project developed coordinated measures addressing these risks, while individual jurisdictions implement those measures through their domestic law and treaty arrangements.

For multinational enterprise groups, BEPS compliance requires more than preparing forms. Transfer-pricing policies, legal agreements, actual conduct, decision-making, people functions and financial data should tell a consistent story. Requirements and thresholds vary by jurisdiction and reporting period, so each group must assess the rules that apply to its entities and transactions.

We help multinational groups translate broad BEPS principles into practical governance, analysis and documentation.

• Assess the group’s operating model, cross-border arrangements and material BEPS risk areas.
• Review transfer-pricing compliance obligations across relevant jurisdictions.
• Compare legal agreements and documented policies with the parties’ actual conduct.
• Analyse how group entities contribute to the development, enhancement, maintenance, protection and exploitation of intangibles.
• Evaluate whether remuneration aligns with functions performed, assets used and risks controlled.
• Coordinate local and global documentation, data sources, owners and filing calendars.
• Train relevant group personnel on documentation requirements and recurring controls.

Tax authorities increasingly use transfer-pricing documentation and jurisdiction-level information to assess whether reported outcomes are consistent with economic activity and value creation. Intangibles and complex cross-border arrangements often require particular attention.

• Location, legal ownership and economic use of intellectual property and other intangibles.
• Where important development and decision-making functions are actually performed.
• Which entities control economically significant risks and have the financial capacity to assume them.
• Whether intercompany payments and returns are supported by the contribution of each entity.
• Consistency among agreements, transfer-pricing policies, financial results and actual conduct.
• Alignment of revenue, profit, tax and indicators of substance across jurisdictions.
• Availability and consistency of data used across local files, the master file and CbC reporting.

BEPS Action 13 established a standardised three-tier approach. Domestic implementation, thresholds, deadlines and notification obligations differ, so applicability must be confirmed for each jurisdiction.

Master file

Provides a high-level picture of the multinational group, including its organisational structure, business activities, intangibles, intercompany financing, financial position and transfer-pricing policies.

Local file

Documents material controlled transactions of the local entity, including the parties, amounts, functional analysis, transfer-pricing method and supporting financial information.

Country-by-country report

Reports specified aggregate information by tax jurisdiction, including revenue, profit, taxes and indicators of economic activity. Tax administrations use it for high-level transfer-pricing and BEPS risk assessment; it is not a substitute for a detailed transfer-pricing analysis.

Our services are scoped to the group’s structure, transactions, jurisdictions and applicable domestic requirements.

• BEPS and transfer-pricing readiness diagnostic.
• Master file, local file and CbC reporting coordination.
• Functions, assets and risks interviews and documentation.
• Intangibles and value-creation analysis, including DEMPE contributions.
• Review of intercompany agreements and actual conduct.
• Documentation consistency and data-reconciliation review.
• Compliance calendars, governance processes and controls.
• Training and knowledge-sharing sessions for group teams.

We connect global documentation with the local facts that support it. Our approach focuses on consistency among the operating model, interviews, agreements, financial data and transfer-pricing positions. Deliverables include clear responsibilities, information requests and review points so the group can maintain its compliance process after the initial engagement.

BEPS implementation differs across jurisdictions and changes over time. Advice is therefore based on the entities, transactions, reporting period and law within scope, with local specialist input where required.