Deloitte’s 2020 global BEPS survey on the OECD’s Base Erosion and Profit Shifting (BEPS) initiative and the next wave of Global Tax Reset provides valuable insight into the strategies of some of the world’s largest multinational companies in the face of changes to the international tax framework. The survey gauges the attitudes of multinational and Swiss tax leaders towards the expected impact on their organisations of increased media, political, and activist group interest in tax and investigates how multinationals are addressing the impacts of the OECD’s Pillar One and Pillar Two projects and the challenges of a changing global tax landscape.

What's on the minds of tax leaders – global and Switzerland key findings

Our survey suggests the impacts of the BEPS project and other tax reform initiatives will be felt for the foreseeable future as more measures begin to take effect and are embedded into local laws.

Tax governance remains high on the Board’s agenda

•  71% of global respondents and 65% of Swiss respondents are concerned about media coverage and political and activist group interest in corporate taxation. Consequently, C-suite involvement in organisations’ tax strategies has remained consistently high in recent years.
•  60% of companies globally and 50% of Swiss companies have implemented additional corporate policies and procedures in response to increased scrutiny of corporate taxation.

Taxation of the digital economy remains a ‘hot topic’

• 44% of global respondents and 40% of Swiss respondents expect a global consensus to lead to changes in taxation of the digital economy.
• 31% of tax globally and 55% of Swiss tax leaders have been actively engaged in the OECD’s Pillar One/ Pillar Two project consultation.
• More than half of global respondents (62%) and Swiss respondents (65%) are concerned that the OECD’s Pillar One / Pillar Two project may lead to an increase in their corporate tax liability.

Cross-border coordination has room to improve

• Only 23% of tax leaders globally and 35% of Swiss tax leaders agree that most tax administrations will interpret the changes to the Transfer Pricing Guidelines in a consistent manner.
• 57% globally and 55% in Switzerland agree or strongly agree that their organisation is concerned about lack of guidance from tax authorities about the Principal Purpose Test (PPT).

Businesses are slowly securing additional resources to deal with BEPS-related changes

• Despite the unprecedented degree of change in tax laws worldwide, only 32% of organisations globally and 30% of Swiss companies have secured (or plan to secure) additional resources/headcount for their tax group.
• Only 24% of global respondents and 5% of Swiss respondents have or intend to co-source or outsource further tax group functions due to BEPS-related changes.
• Increased investment in tax-related technology appears more prominent; 47% companies globally and 50% Swiss companies have increased their investment in technology to cope with the volume of BEPS-related changes.

The impact of COVID-19

The survey was conducted before COVID-19 spread across the globe. The findings therefore reflect the pre-pandemic views or plans of respondents.

Research scope

Conducted in early 2020, Deloitte’s seventh annual global BEPS survey, which involved 296 global tax leaders in 38 countries, focused on multinational tax leaders’ experiences with BEPS and the next wave of Global Tax Reset, including the impact of implementation and consequential developments within their organisations.

Download the Deloitte’s 2020 global survey FULL REPORT
Download the EXECUTIVE SUMMARY
Download the SUMMARY OF THE SURVEY DATA

Which tax policies have the most bearing on Switzerland’s long-term success? Where do government and businesses have the greatest scope to boost Switzerland’s competitiveness, productivity and progress? Learn more in our latest Deloitte Power up Switzerland publication.

Blog contributor: Michelle Chan, Marketing Lead, Tax & Legal Switzerland

If you would like to discuss more on this topic, please do reach out to our key contacts below:

Key contacts

Reto Gerber - Managing Partner, Tax and Legal Deloitte Switzerland

Reto Gerber is a tax partner with more than 22 years of experience with a focus on transaction related tax matters such as acquisition structures, due diligence work (buy-& sell-side) as well as tax advice on SPA and management participations plans. He also advised on a number of tax efficient principal structures for multinational groups.

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Martin Krivinskas -  Partner, Transfer Pricing 

Martin is an international tax partner with 20 years experience working on international tax matters. He has worked extensively with global multinationals, with a particular focus on helping international group’s mitigate tax risk and manage their effective tax rates. Martin has significant experience of supporting clients with a wide range of transfer pricing and international tax matters and is part of Deloitte` s Global Value Chain Alignment leadership team. Martin`s clients are predominantly in the life sciences, industrial products and consumer products industries.

Martin is a Chartered Accountant and a member of the Chartered Institute of Taxation

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Salim Damji - Partner, Transfer Pricing 

Salim Damji joined Deloitte Switzerland as a Transfer Pricing and VCA Partner in our Zurich office from another Big Four firm in Switzerland. Salim has been a Big Four firm’s partner for approximately 14 years. He primarily works with Swiss groups to assist them in developing transfer pricing models which are globally sustainable, Advance Pricing Agreements, Mutual Agreement Processes, and Business Restructuring issues. Salim, who works extensively in the field of Intellectual Property, started his career in the UK, before moving to Switzerland in 2005 and worked in the UK, USA, and Switzerland. He holds degrees from Oxford University and Southampton University. .

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Daniel Stutzmann - Partner, International Tax

Daniel is a Tax Partner with more than 15 years of experience as an international corporate tax specialist. This includes a one year assignment in the US to lead the Swiss ICE Desk. Daniel has extensive experience in the area of cross-border structuring (like establishing tax efficient IP- and financing structures) as well as business reorganizations including large supply chain transformation projects. This also includes advising several multinationals in moving their worldwide/regional headquarters or central functions to Switzerland, while often establishing tax privileged Swiss principal companies. In his capacity as Swiss tax expert he has worked on a significant number of value chain alignment (“VCA”) projects, cross border restructuring and headquarter relocations.

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