BEPS: fixing the Permanent Establishment problem will not be easy, warns Moore Stephens


Prague, 30. 3. 2015: The OECD and the G20 may face an uphill task in tackling tax avoidance through artificial manipulation of permanent-establishment status, says professional services network Moore Stephens.

The OECD’s BEPS Action Plan 7 aims to recommend treaty-based amendments to prevent international companies operating in a country from artificially avoiding having a permanent establishment there, thus limiting their liability to corporate tax in that country.

According to a survey in leading developed countries recently carried out by the Tax Faculty of Moore Stephens Europe, the main obstacles to the OECD Action Plan are as follows:



“Given these differences,” says Věra Jankovcová Tax Partner of Moore Stephens, “even if the OECD, the G20 and the EU are able to reach unanimous agreement in their professed attempt to create fairer taxation of multinational transactions, it will take a very long time for the necessary changes to be implemented. Furthermore, there would even in that event be no guarantee that all mismatches and planning opportunities would disappear or even that new discrepancies would not be created.”


Tereza Juráková


— End of press release —


About BEPS

Launched in 2013, the BEPS (Base Erosion and Profit Shifting) Action Plan of the OECD (Organisation for Economic Development and Cooperation) aims to tackle tax avoidance and mitigation by multinational companies and to ensure a fairer allocation of tax revenues between the countries in which these companies operate, and is backed by the G20 and the European Union.


For more details, consult the Moore Stephens Tax Faculty report (in English, on request).


About Moore Stephens

Moore Stephens is one of the leading consulting firms operating on the Czech market. We help to solve specific financial, accounting, tax and legal issues, we tailor all solutions specifically to our clients. Our team of more than 80 experienced professionals is ready to take over both your everyday worries and long-term strategic goals. We have offices in Prague, Pilsen and Domažlice – we are therefore always at your disposal. Find out more on



Contact person

Tereza Juráková
Marketing & communications

T +420 255 708 336
M +420 731 424 785
Office Park Nové Butovice – Building D
Bucharova 1314/8 | Prague 13 | 158 00


© 2019 Moore Stephens. All rights reserved. Sitemap Privacy Policy Design by aboutblank - creative web design