Some commentators say the OECD project to tackle “base erosion and profit shifting” does not go far enough. Others say the timetable is too ambitious, or that the project is doomed to fail.
So if you were on the OECD panel presenting this update, you would want to look confident. If you don’t have time to watch the whole webcast, watch Raffaele Russo (at 49 minutes or so) tell the world that the days of the “double Irish” are numbered.
A journalist asked about “growing speculation that high tech companies with intellectual property in countries like Bermuda will end their ‘double Irish’ structures as a result of the proposed transfer pricing changes that would reduce the profits that can be attributed to countries where there’s nothing other than legal ownership”.
Russo, head of the BEPS project, said: “Yes, that is what’s going to happen. There are a number of measures that are being developed in the course of the BEPS project … that effectively will put an end to stateless income or nowhere income. So all the structures that aim at achieving this effect will become ineffective once these measures are implemented.”
Now watch the smile on the face of Pascal Saint-Amans, sitting next to Russo. It’s fair to say that the OECD seems pretty confident on this issue …