Introduction

Base Erosion and Profit Shifting (BEPS) Impacts Training Course provides an in-depth understanding of the OECD/G20 BEPS framework and its implications on multinational enterprises (MNEs). Participants will explore strategies used by corporations to shift profits and minimize tax liabilities, as well as the global efforts to counter such practices through transparency, substance, and fairness. The course examines the 15 BEPS Action Plans and their implementation across various jurisdictions.
By the end of this course, participants will have a clear understanding of the compliance obligations, tax risks, and strategic responses associated with BEPS regulations. This program also delves into the evolving landscape of international tax cooperation, the digital economy’s challenges to traditional tax systems, and how countries are implementing minimum global tax standards. Participants will learn how to evaluate intercompany transactions, identify aggressive tax planning structures, and adopt best practices to mitigate BEPS-related risks. The course integrates real-world case studies from multinational corporations, providing insights into regulatory enforcement and dispute resolution under BEPS frameworks.

Programme Curriculum

Base Erosion & Profit Shifting (BEPS) Impacts Training Course

Introduction

Course Objectives

By the end of this training, participants will be able to:

Understand the concept, objectives, and scope of the BEPS initiative.
Identify the 15 BEPS Action Plans and their implications on corporate tax structures.
Evaluate how BEPS affects transfer pricing, digital taxation, and profit allocation.
Interpret country-by-country (CbC) reporting requirements and global transparency measures.
Analyze double tax treaty abuse and anti-avoidance mechanisms under BEPS.
Assess the impact of BEPS on global value chains and multinational tax planning.
Examine tax policy reforms and compliance strategies across different jurisdictions.
Manage tax risk exposure and align corporate practices with international standards.
Understand the role of Pillar One and Pillar Two in the global minimum tax debate.
Review practical case studies of BEPS audits and enforcement actions.
Formulate corporate governance strategies for BEPS compliance.
Strengthen internal reporting and documentation practices for tax transparency.
Develop an action plan for ongoing monitoring and implementation of BEPS measures.

Target Audience

This course is designed for:

Tax Directors and Managers
Chief Financial Officers (CFOs)
Transfer Pricing Specialists
Legal and Compliance Officers
Financial Analysts and Auditors
Policy Advisors and Regulators
Accountants and Consultants in Multinational Firms
Tax Administrators and International Tax Practitioners

Course Duration: 5 days

Course Modules

Module 1: Overview of BEPS and Its Global Impact

Understanding the origins and evolution of BEPS
OECD/G20 framework and objectives
Global tax fairness and transparency initiatives
Key challenges in combating base erosion
The impact on multinational tax strategies
Case Study: OECD BEPS implementation in the EU

Module 2: The 15 BEPS Action Plans Explained

Overview of each BEPS Action Plan
Actions addressing harmful tax practices
Transfer pricing documentation requirements
Prevention of treaty abuse
Implementation challenges and local adaptations
Case Study: BEPS Action 13 – Country-by-Country Reporting

Module 3: Transfer Pricing and BEPS Implications

The link between BEPS and transfer pricing
Risk assessment and functional analysis
Profit allocation and arm’s length principle adjustments
Transfer pricing documentation under BEPS
Managing intercompany transactions
Case Study: Multinational transfer pricing audit under BEPS rules

Module 4: Digital Economy and BEPS

Tax challenges arising from digitalization
Pillar One: Reallocation of taxing rights
Pillar Two: Global minimum tax framework
Digital services taxes (DSTs) and global responses
Compliance strategies for digital businesses
Case Study: BEPS implications for global tech companies

Module 5: Tax Treaties and Anti-Avoidance Measures

BEPS impact on tax treaties and the Multilateral Instrument (MLI)
Treaty shopping and hybrid mismatch arrangements
Controlled Foreign Company (CFC) rules
Limitation of benefits (LOB) clauses
Withholding taxes and double taxation prevention
Case Study: Analysis of the BEPS MLI in cross-border treaties

Module 6: Compliance, Reporting & Documentation

Country-by-country (CbC) reporting requirements
Master file and local file documentation
Data management and confidentiality
Reporting obligations for MNEs
Tax authority audits and information exchange
Case Study: Managing CbC compliance in a global corporation

Module 7: BEPS Risk Management & Corporate Governance

Identifying and managing BEPS-related risks
Internal controls and corporate governance structures
Aligning tax policy with business strategy
Monitoring BEPS updates and compliance deadlines
Integrating BEPS in risk management frameworks
Case Study: Internal governance model for BEPS compliance

Module 8: Future of BEPS and International Tax Cooperation

Post-BEPS global tax landscape
Role of the Inclusive Framework and global cooperation
BEPS 2.0 and the evolving digital economy
Policy implications for developing economies
Strategic implications for multinationals
Case Study: BEPS 2.0 – Global Minimum Tax implementation outcomes

Training Methodology

Interactive lectures and guided discussions
Real-world case study analysis
Group-based practical exercises
Hands-on tax documentation and compliance simulations
Policy interpretation and regulatory framework review
Knowledge checks, Q&A sessions, and expert feedback

Register as a group from 3 participants for a Discount

Send us an email: info@fineskilltrainingcenter.org or call +254769199797

Certification

Upon successful completion of this training, participants will be issued with a globally- recognized certificate.

Tailor-Made Course

We also offer tailor-made courses based on your needs.

Key Notes

a. The participant must be conversant with English.

b. Upon completion of training the participant will be issued with an Authorized Training Certificate

c. Course duration is flexible and the contents can be modified to fit any number of days.

d. The course fee includes facilitation training materials, 2 coffee breaks, buffet lunch and A Certificate upon successful completion of Training.

e. One-year post-training support Consultation and Coaching provided after the course.

f. Payment should be done at least a week before commence of the training, to Fineskill Training Center account, as indicated in the invoice so as to enable us prepare better for you.

Programme Fee

Duration: 5 Days

Method: Online or Physical

Online Price: $1,000

Physical Price: $1,500

Certification: Accredited Certificate

View Available Dates 📄 Download Course Outline (PDF)

Available Sessions

Location

Month

Year

Oct 19 2026

19 Oct — 23 Oct 2026

💻 Online / Virtual session

Online $1,000