Base Erosion and Profit Shifting (BEPS) 2.0

How will the BEPS 2.0 proposals of the OECD/G20 Inclusive Framework impact multinational enterprises?

How will the BEPS 2.0 proposals of the OECD/G20 Inclusive Framework impact....

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The BEPS 2.0 measures are designed to deal more effectively with contemporary multinational business structures. They aim to address situations where a business can play a substantial role in a national economy without having a physical presence there.

The measures are comprised of two Pillars:

Pillar 1 – Applies to certain highly profitable multinational enterprise (MNE) groups with global revenue exceeding EUR 20 billion and return on sales above 10% (excluding extractives and regulated financial services)
Pillar 2 – Applies to MNE groups with global revenue of at least EUR 750 million in 2 of last 4 years (excluding pension funds, government organizations and investment entities)

KPMG can help companies analyse the impact of BEPS 2.0 on their business and respond to new BEPS proposals.

How KPMG can help

Globally connected, KPMG can assist companies to understand the implications of BEPS through:

Advisory support

We help organisations navigate through complex rules, including the impact on group structures, financing and value chains.

Impact assessment and data management

We assist organisations evaluate their data challenges using our KPMG’s BEPS 2.0 Automation Technology (KBAT) to identify data gaps and build plans for future compliance.

Project support

We help with planning BEPS 2.0 responses and provide resource support, including governance assessments, facilitating communication with stakeholders and managed service support.

BEPS: Frequently asked questions

Understanding the potential impact of the BEPS 2.0 proposals is vital to how your organization proceeds. KPMG's BEPS 2.0 Automation Technology (KBAT) can enable you to assess the likely impact and degree of focus needed to respond effectively to the challenges that the BEPS 2.0 proposals may pose to your business.

Project plans are not just about working out the impact on your organisation. Engagement with internal and external stakeholders, resource requirements, accounting interactions, impact on governance and controls, domestic regulator engagement, systems/data and business restructuring are all key areas to build into any plan. We can work with you to develop a holistic plan and provide resourcing support as you begin your BEPS 2.0 journey.

The BEPS 2.0 changes are expected to lead to some simplification of group structures and value chains. Domestic minimum taxes, unwind of incentives and jurisdictional blending may lead to centralising some operations and decentralising others. KPMG can assist with restructuring services, and our experienced tax and legal teams work with you to look at ensuring group structures, financing arrangements and supply chains are fit for the future.

Many multinational groups have been surprised with the level of complexity and data needed to comply with the rules, with compliance processes needed even if no top up tax is ultimately payable. KPMG’s BEPS 2.0 Automation Technology can be used to identify the data gaps, and KPMG can work with you to resolve these. Operating models can then be designed based on source systems, reporting needs and resource constraints.