Briefly describe Indicators of BEPS activity recommended under action plan 11 of Base Erosion and Profit Shifting (BEPS).

CA Final · Direct Tax Laws and International Taxation · PYQS · September 2025
Briefly describe Indicators of BEPS activity recommended under action plan 11 of Base Erosion and Profit Shifting (BEPS).

Suggested Answer and Working Notes:

Under Action Plan 11, there are six indicators of BEPS activity which are described below: (1) The profit rates of MNE affiliates located in lower-tax countries are higher than their group's average worldwide profit rate. (2) The effective tax rates paid by large MNE entities are estimated to be lower than similar enterprises with only domestic operations. (3) Foreign direct investment (FDI) is increasingly concentrated. (4) The separation of taxable profits from the location of the value creating activity is particularly clear with respect to intangible assets, and the phenomenon has grown rapidly. (5) Royalties received by entities located in these low-tax countries accounted for 3% of total royalties. (6) Debt from both related and third-parties is more concentrated in MNE affiliates in higher statutory tax-rate countries.

Topics: Application and Interpretation of Tax Treaties

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