Problem: During its change management meeting, senior management of your tax authority agreed to carry out sensitization workshops for staff on the issues of Base Erosion and Profit Shifting (BEPS) in order to enhance ensure enforcement of some BEPS milestones. You have been asked to prepare a concept paper for the Commissioner-General to use for the official opening of the workshop. You are required to provide answers to the following questions:
1. What was the reason for BEPS?
2. What has the impact of the OCED BEPS project been?
3. What are the latest proposals on countering treaty abuse?
4. Are the provisions on treaty abuse significant or are they similar to existing treaty shopping provisions?
5. How does BEPS affect advance pricing agreements?