BEPS: sample domestic policy responses.

• Position: THE BACK PAGE - Reprint

BEPS Sample Domestic Policy Responses COUNTRY PROPOSAL EFFECTIVE DATE Mexico Deduction for royalty and January 1,2014 interest disallowed unless "subject to tax" in recipient state Double deductions by two related parties on single payment disallowed Treaty benefit only allowed with affidavit evincing double taxation France Deduction disallowed for FY ending on or after low-taxed related-party September 25,2013 interest expense Germany Dividend exemption FY beginning disallowed on hybrid January 1,2014 dividends Australia Interest deductions limited Taxable year beginning by new thin cap rules after July 1,2014 GAAR and transfer pricing 2013-14 rules recently strengthened to prevent shifting of profits offshore Austria No deduction for payments March 1,2014 that are not "sufficiently" taxed or are not taxed at all at the level of the recipient. A tax rate of 10% at the level of the recipient will be considered sufficient for these purposes Investigation European Commission has Generally no by European begun preliminary fixed deadline Commission investigation of whether tax rulings...