Shall international tax planning drop drammatically by virtue of BEPS? It depends

Shall international tax planning decrease after the implementation of BEPS? The reply is “depends” by virtue of the subject’s exposure to several variables. Obviously, one should consider the question in the light of the legislative framework and tax environment of the relevant country which is in principle the country for which tax planning is being done. For a multinational company, it may be the State of residence of a subsidiary if the tax planning is targeted at reduction of source State taxation. Conversely, tax planning may also be looked at in the country of residence of the parent company when residence tax is at stake in the tax planning exercise such as escaping CFC rules or otherwise enhancing deferral of corporate tax liability. Depending on the targeted country for the tax planning, the reply to the question ("shall international tax planning drop?") may change.