We’re a year or two off, and missing some detail, but you may need to provide far more information than you currently do to the tax authorities, in the form of a ‘master file’ which will be shared with the countries in which you operate.
Depending how you operate, you may also need a tax presence in some of the countries in which you operate.
BEPS bring particular challenges to digital businesses, and we’ll be running a short seminar/workshop on the topic at Blu Sky HQ in January.