What does BEPS really mean for TP recruitment?
04 April 2016
October 5th 2015. Will you look back and remember what you were doing on this day 10 years from now? A lot of Transfer Pricing practitioners may very well do exactly that. 
Just another day? Possibly - for a lot of people; but for TP professionals around the world, October 5th 2015 could well represent one of the most pivotal days in one’s career. This was the day the Organization for Economic Co-operation and Development (“the OECD”) finally released its final package of Base Erosion and Profit Shifting (“BEPS”) measures to the world. 
Undertaken at the request of the G20, the work to tackle BEPS is based on the 2013 OECD/G20 BEPS Action Plan, which identified 15 actions to curb international tax avoidance. The package of measures is structured around three fundamental pillars: 
1. Introducing coherence in the domestic rules that affect cross-border activities; 
2. Reinforcing substance requirements in the existing international standards, to ensure alignment of taxation with the location of economic activity and value creation; and 
3. Improving transparency, as well as certainty for businesses and governments.
The culmination of 2 years work – proposals, discussion, debate, drafting, consultation, re-drafting, more debate, more re-drafting, more consultation and final drafting – you get the picture. 
Many TP professionals were skeptical. Surely an action plan involving 15 items concentrating on fixing some fundamental ‘flaws’ in the global international tax framework followed by some of the largest economies in the world, couldn’t be dealt with in a mere two years? Well, here we are 2 years later and BEPS is well and truly a part of any TP professional’s daily life. It is a reality. But what does this mean for TP professionals and their careers?
Arguably, the introduction of BEPS will present a wealth of opportunities for TP practitioners the world over. During the next 2 years and beyond, there will be considerable shadow boxing between taxpayer’s, their external advisors and Tax Authorities around the world. What will really be required under Country by Country Reporting (“CbCR”)? How will the requirements actually be interpreted (or mis-interpreted) by all the interested parties? Who is going to collate all the data? Do we just rely on our advisors at first? Do we need to hire permanent headcount to deal with all of this change? Do we really need a “new” software solution – surely we have all the information; don’t we just need someone to find it and extract it from our current IT systems? 
These aren’t random questions – they are questions that have been raised by clients and candidates we work with on a daily basis, all around the world. This clearly demonstrates that BEPS has brought with it, anything but certainty. Like anything new, be it legislation, rules, regulations or guidelines – until tested, examined or probed, the only thing that is certain, is uncertainty. 
Herein lies the opportunity. Until a full reporting cycle under BEPS has been endured and until Tax Authorities start reviewing the mountains of documents and data that will come pouring in from MNC taxpayer’s all around the world, TP professionals, whether they be in-house, consulting or working in a Tax Authority somewhere, will be working around the clock to address the requirements of BEPS relative to their proverbial side of the fence. This clearly means that there will be much more work to do; whether it be reviewing current or past structures or transactions to assess for future risk exposure or merely ensuring compliance with the guidelines moving forward, there is a lot to do.
At TP International we have already seen the impact. New mandates and new clients are approaching us every day to assist with finding the best Transfer Pricing talent around the world. However, this does not mean that every TP professional has won Willy Wonka’s golden ticket; certainly not. Transfer Pricing professionals, more than ever before, will need to bring their “A” game, to any recruitment process. 
The demand to relocate from one’s home country to gain valuable international experience abroad in the developing BEPS environment is higher than ever. This means that there are more professionals currently looking for opportunities than at any other time in the history of Transfer Pricing. Competition for jobs is fierce and employers are scrutinizing applications far more closely than in previous years.  
Similarly though, employers – please take note: Candidates now have multiple and often global choices available to them in the market.  Therefore hiring firms need to be sharp and focused to ensure they have the slickest recruitment process around because like it or not, be it right or wrong, the recruitment process is seen by candidates as an absolute reflection of how the business is run and what working at the new firm will be like. Run a slow, disjointed and unimpressive recruitment process and you can wave goodbye to the top tier of candidates – they will be waving back at you from the office window of your competitors who were able to run a smooth, decisive and inspiring recruitment process. Our message really is that simple.
The next 2-5 years promise to be full of exciting times for TP professionals and we look forward to continuing to work with our existing and new clients and candidates throughout this groundbreaking period.
For employers seeking to recruit new talent into this discipline or for individuals interested in having a confidential career discussion, please do not hesitate to contact Liz or Aaron at: lt@tpi-search.com or al@tpi-search.com and we will delighted to help in any way we can.