A focus on hybrid arrangements, interest deductions, treaty abuse and permanent establishment structures.

On 5 October 2015, the OECD published its highly anticipated final reports in relation to Base Erosion and Profit Shifting (BEPS). The reports are the culmination of a two-year project that began with the Action Plan on BEPS which G20 Leaders endorsed in July 2013. The project considers 15 action points, aimed at addressing increasing international concern at multinational enterprises avoiding taxes through BEPS and aggressive tax planning. More than 60 countries participated in the BEPS project, and participating countries have agreed a comprehensive package of measures which, together, could result in significant changes to taxation regimes internationally.