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The OECD’s Base Erosion and Profit Shifting (BEPS) agenda is fundamentally disrupting the way the Private Equity (PE) sector has always worked – but with change comes opportunity.

Each of the 15 BEPS actions are important, but here is just a taster to illustrate how just a few of them will impact the PE sector:

Action 4, which limits the amount of net interest expense that a business can deduct against profits (in most countries to 30% of taxable earnings before EBITDA)

Action 7, designed to prevent the artificial avoidance of ‘permanent establishment’ status,

Actions 8, 9 and 10, which collectively align transfer pricing with value creation, and