Addressing the tax challenges of the digital economy. The fiscal authorities appear to be behind the curve in understanding how the digital economy operates in terms of the features that drive profitability, and therefore they are not allocating value to different activities correctly. A study is proposed to examine this further.

Neutralising the effects of debt mismatching; for example, where certain instruments can be treated as generating (tax deductible) interest in the payer jurisdiction but (tax exempt) dividends in the recipient jurisdiction.

Strengthening controlled foreign company (CFC) rules in the jurisdiction of the (high tax) ultimate parent. Under CFC rules, the profits of a low tax subsidiary are taxed as they accrue, as opposed to when they are distributed. They can disincentivise the use of low taxed intermediate subsidiaries and local tax minimisation, as there is no point in reducing taxes at the local level if the parent jurisdiction is taxing profits as they arise. For example, the absence of an effective CFC regime in the US iscompanies to minimise their non-US taxes globally and retain profits outside the US.

Developing limitations on the use of intra-group interest payments; for example, where the corresponding receipt is taxed at a low rate and the amount of debt is excessive compared to the overall external debt levels of a group, or where the debt is used to generate deferred or exempt income.

Evaluating the preferential regimes that are offered in some jurisdictions for particular income sources (for example, intangibles such as the "patent box" regime introduced by a number of European countries, including the UK (see feature article "Patent boxes: making the most of the new regime"). In particular, the degree of substance required locally in the relevant jurisdiction in order to benefit from the preferential regime will be examined by the OECD in conjunction with non-OECD members.

Preventing multiple layer conduit structures that potentially enable tax treaty abuse in relation to global supply chains; for example, where a conduit company does not have real economic involvement in a transaction chain.

Preventing the artificial avoidance of permanent establishment (PE) status. Profits from sales to customers in a jurisdiction are normally only taxed if the vendor has a PE. Where a "commissionaire" structure (as opposed to distributor structure) is used, there will normally be no local PE. This is because under such arrangements the contracts are made outside the jurisdiction of the sale (and so are not taxed there), even though staff of a local subsidiary may be involved in organising the sale. Another exemption from the PE rules is for local warehouses: in the digital world, the ability for goods to be delivered promptly to local customers is essential, and therefore the historic exemption will be reconsidered to see whether it is still valid in today's market.

Devising alternative methodologies to ensure that, in the context of transfer pricing, profit is allocated fairly between different jurisdictions. Identifying a proper price is difficult in a number of transfer pricing situations, in particular:

Collecting and analysing data relating to BEPS.

Ensuring taxpayer transparency, possibly including mandatory disclosure rules for "international tax schemes".

Including in the requirement to substantiate transfer pricing methodologies an obligation to disclose global allocation of income, economic activity and taxes paid, based on a common template.

Reviewing constraints on mutual agreement procedures and arbitration, which inhibit fiscal authorities acting in a joined-up manner.

Developing a multinational instrument to effect changes to tax treaties, obviating the need for each agreement to be amended unilaterally. This measure is proposed due to the inherent difficulty in implementing changes to international tax rules, even once a consensus has been reached on what changes are to be made.

Related party finance arrangements.

Transfer pricing for intangibles.

OECD requirements for documents to include transfer pricing strategy documents.