Operations & compliance
BEPS
BEPS stands for Base Erosion and Profit Shifting, the OECD-led project launched to close gaps that let multinational groups artificially shift profit into low-tax jurisdictions, and it reshaped transfer pricing practice through fifteen action points covering documentation, intangibles, risk allocation and dispute resolution.
For transfer pricing specifically, BEPS introduced the three-tier documentation structure of master file, local file and country-by-country report, tightened the analysis of risk and intangible ownership so pricing follows where value is genuinely created, and pushed substance requirements much higher up the agenda.
Most jurisdictions have now implemented BEPS-aligned documentation and reporting rules domestically, meaning groups can no longer treat transfer pricing as a paperwork exercise completed once a year, since the underlying substance behind each intercompany arrangement is now expected to match what the documents describe.
In practice
What matters when applying beps
- Know the fifteen BEPS action points at a high level
- Align documentation with the three-tier structure
- Match substance to functions described in files
- Track domestic BEPS implementation by country
- Watch for BEPS 2.0 developments like Pillar Two
Frequently asked
Common questions
What is the core aim of BEPS?+
BEPS aims to stop multinational groups shifting profit into low-tax jurisdictions without matching real economic activity, by tightening transfer pricing and disclosure rules globally.
How does BEPS affect documentation requirements?+
BEPS introduced the three-tier master file, local file and country-by-country reporting structure that most jurisdictions have now adopted into domestic transfer pricing law. This matters in practice.
See how the tooling handles this in practice
Our transfer pricing tools calculate intercompany charges, benchmark financing and reconcile the intercompany ledger from your own data. Book a short walkthrough and we will show the workflow on a scenario that matches your group structure, rather than a generic demo dataset.