As predicted It hasn't taken long for the  self serving "discussion" over the BEPS strategy to start . 

There is a fear in the US  that the initiative  will be a catalyst for  US businesses to relocate to other jurisdictions to avoid the outcome of double taxation  and rising compliance costs . The concerns are varied and include country by country reporting requirements . In addition to the reporting aspects the prospect of shifting the point of taxation may have a major impact on the US tax take. Interestingly , various surveys have shown that business acknowledge that the current rules are no longer fit for purpose .

The cooperation of some 90 plus jurisdictions , to implement the entire plan is likely to require a time frame of 5 years + according to the Australian Taxation Office response yesterday .The Australian position is to keep engaging with overseas investors to encourage economic activity while being mindful of the entire picture . i.e Australia is aware that everyone needs to be able to preserve their own tax base based on the economic activity .While it sounds positive , and there appears to be the political appetite to address the global tax problem  the question will always be , which part of the economic  activity is ( more ) relevant . The customers location, the producers location etc .and what will it cost "us" in revenue dollars without shredding the revenue base in favor of  other locations. A real concern is that of unilateral actions taken by jurisdictions which could very well undermine and slow down the project on a multi lateral level .While various jurisdictions may not act unilaterally , the pace of change will mean that there is a risk of a compromised outcome in the next few years . 

What is clear despite the uncertainty , which is considerable at the moment , the world has changed and the rules as we knew them , have been consigned to history. Based on this new landscape larger businesses need to consider their current models  .This includes likely reporting requirements  and what transparency of data means to the business world and competition . Who will see the data  . There is also the issue of the reality that tax compliance costs  will increase  considerably .

Critically , what will increase , is the tax take  which will impact on the profit levels previously enjoyed by business. The challenge therefore is to ensure that under the new world order that is emerging , the strategy will be focused on minimizing  double taxation . What we will see is that existing operations are likely to face  considerable rearrangement and management must start now to get a handle on these issues.