Decade of Reflections on the First OECD BEPS Program: Salvation or Condemnation for Financial Transactions?

Martin Druga and Maria Zvonarjova

FinanzArchiv: Public Finance Analysis, 2025, vol. 81, issue 3, 299-332

Abstract: The examination of the OECD BEPS initiative, particularly Actions 4 and 8-10, reveals positive strides in the realm of international tax regulation aimed at curbing base erosion and ensuring that multinational companies' profits are aligned with where value is created. Action 4 introduced limitations on interest deductions, while Actions 8-10 brought updates to transfer pricing rules, emphasizing economic substance. Although there has been significant progress, there remain complexities, such as heightened compliance requirements and intricate tax issues, highlighted by the subtleties in the Dutch system and exemplary treatment of cash pooling. The analysis underscores the need for a balance between theoretical tax models and their practical application within business operations, suggesting ongoing revisions to international standards to maintain equitable and effective tax systems. As local tax regulations, including the Dutch transfer pricing landscape, continue to adapt through initiatives like BEPS 2.0, there is an encouragement for the OECD to further refine its guidelines to ensure they are both pragmatic and equitable.

Keywords: OECD BEPS actions 4 and 8-10; financial transactions; transfer pricing (search for similar items in EconPapers)
JEL-codes: H20 K34 (search for similar items in EconPapers)
Date: 2025
References: Add references at CitEc
Citations:

Downloads: (external link)
https://www.mohrsiebeck.com/en/article/decade-of-r ... s-101628fa-2026-0002
Fulltext access is included for subscribers to the printed version.

Related works:
This item may be available elsewhere in EconPapers: Search for items with the same title.

Export reference: BibTeX RIS (EndNote, ProCite, RefMan) HTML/Text

Persistent link: https://EconPapers.repec.org/RePEc:mhr:finarc:urn:doi:10.1628/fa-2026-0002

Ordering information: This journal article can be ordered from
Mohr Siebeck GmbH & Co. KG, P.O.Box 2040, 72010 Tübingen, Germany

DOI: 10.1628/fa-2026-0002

Access Statistics for this article

FinanzArchiv: Public Finance Analysis is currently edited by Alfons Weichenrieder, Ronnie Schöb and Jean-François Tremblay

More articles in FinanzArchiv: Public Finance Analysis from Mohr Siebeck, Tübingen
Bibliographic data for series maintained by Thomas Wolpert ().