Estimating an impact of base erosion and profit shifting (BEPS) countermeasures — a case of business group

Research background: Base erosion and profit shifting (BEPS) is a reduction of corporate income tax base and related corporate income tax payments via taking advantage of tax loopholes. OECD prepared 15 BEPS actions, which set countermeasures to fight tax avoid-ance in a coordinated way and shall be implement by countries on a voluntary basis. Literature review revealed that on a macro-level and company-level the extent of BEPS is large and statistically significant while studies addressing micro-level (transaction-level) impact and BEPS countermeasures’ related issues are limited. Purpose of the article: to identify methods and metrics available for evaluation of BEPS countermeasures’ impact on a micro-level and to assess BEPS countermeasures’ impact on a business group. Methods: the paper employs comparative analysis of scientific and professional literature to identify approaches and methods available for evaluation of BEPS countermeasures’ impact on a micro-level; and a case analysis method to assess an expected impact of BEPS coun-termeasures on a specific business group. Findings & Value added: An approach used to estimate BEPS countermeasures impact on the micro-level differs from the one applied in macro-level analysis. To conduct the case analysis, OECD’s proposed macro-level fiscal impact assessment approach has been adapted for a micro-level analysis. It includes the analysis of the transactions subject to BEPS countermeasures and develops an action plan to manage related risks. The conducted case analysis differs from previous research as it employs transaction-level data and estimates fiscal effect of BEPS countermeasures on a micro-level. Analysis of the activities of the specific business group revealed that 5 from 15 countermeasures are relevant and directly applicable to this business group. They would not have an immediate significant direct fiscal effect, but risks related to BEPS countermeasures exist and action plans to manage negative effects of BEPS countermeasures have to be implemented.