Written by Graham Iversen.

Proposed changes to international tax rules could have a major impact on private equity structures

In a discussion document published on 21 November 2014, the Organisation for Economic Co-operation and Development (the OECD) has acknowledged an issue which has been causing increasing concern in the international private equity community.

As many readers will know, the OECD has been asked by the G20 Governments to develop a plan for reframing the international tax system. This is the so-called “Base Erosion and Profit Shifting” project (BEPS). The BEPS project has arisen from concerns amongst governments and tax authorities that the international tax system has not kept pace with the development of international business and capital structures. Public outcry and media attention (whether or not well-informed) about the tax affairs of some high profile corporations has pushed this work towards the top of the international political agenda.

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