Resumen de US-based pushback on BEPS

Robert G. Rinninsland, Kenneth Lobo

• The US's Government's main goal is to prevent other countries from taxing what it views as "its" tax base through Base erosion and profit shifting (BEPS). While the US broadly agrees that the issues addressed by BEPS should be remedied, they disagree that a multilateral framework is the best solution for some of these problems.

  In this regard, US lawmakers and regulators have publicly expressed doubt about the progress and effectiveness of the BEPS project. Along with the US corporate community, concerns are that: (i) there are areas of international tax law that are the province of the US and should be managed as such without the layering on top of a newly created set of rules and principles, (ii) the basic tenet of transfer pricing, the arms-length standard, should remain a cornerstone of international tax; and, (iii) US international tax reform is urgently needed to either compliment BEPS Action Plans, to protect US economic interests that would be adversely affected by implementation of BEPS or a combination of both.