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Australia proposes anti-hybrid law to combat multinational tax avoidance, announces plans for “targeted integrity rule”
The Australian government on November 24 released a draft law and explanatory materials implementing hybrid mismatch rules to combat multinational firm tax avoidance. The Australian government is also developing a “targeted integrity rule” to prevent circumvention of the hybrid mismatch rules as well as branch mismatch rules to further clamp down on MNE tax . . .
Multinational
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OECD releases 33 comments to draft guidance on tax treaty access by non-CIV funds
The OECD on March 24 made public 33 letters commenting on draft examples issued last January that address the application of the principal purpose test in tax treaties to non-collective investment . . .
Cabo Verde
Asia-Pacific
Kuwait signs tax transparency agreement
The OECD has announced that Kuwait has signed the CRS Multilateral Competent Authority Agreement, a step required to put into place automatic exchange of financial account information with . . .
Multinational
Tax officials selected to chair OECD global forum and peer review group
Maria José Garde has been appointed as the new chair of the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes and Huey Min Chia-Tern has taken over as chair of the . . .
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OECD releases electronic format for exchange of BEPS country-by-country tax reports
The OECD on Tuesday released a standardized electronic format for the exchange between tax administrations of country-by-country (CbC) reports about multinational . . .
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Americas
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Europe
Greenland is 78th signatory of Multilateral Competent Authority Agreement
Greenland signed the Multilateral Competent Authority Agreement, on December 17, becoming the . . .
Asia-Pacific
Niue signs Multilateral Convention on Mutual Administrative Assistance in Tax Matters
Niue on November 27 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 92nd signatory. . .
Americas
US lawmakers to hold hearings on BEPS, EU State aid cases
(Updated 11/25/2015) The US Senate Finance Committee will consider the OECD/G20 base erosion profit shifting (BEPS) project and the European Commission’s State aid challenges to private tax rulings entered into between EU States . . .
Multinational
OECD releases 50 comments to BEPS discussion draft on dispute resolution mechanisms
The OECD on January 19 released comments to a discussion draft under action 14 of the base erosion profit shifting (BEPS) plan dealing with making cross-border tax dispute resolution mechanisms more . . .
Europe
Switzerland signs agreement for automatic exchange of information
Switzerland on November 19 signed a multilateral competent authority agreement, moving the country one step closer to adopting automatic exchange of financial account information under the OECD/G-20 Common Reporting Standard beginning 2018 . . .
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OECD approves revisions to the Model Tax Convention
The OECD Council, on July 15, approved a 2014 update to the OECD Model Tax Convention. The update modifies Article 26 on exchange of information to allow for group requests. Changes are also made to the meaning of “beneficial owner” for purposes of the OECD Model Convention; to tax treaty issues related to emissions permits and credits; to the tax treaty treatment of termination of employment payments; and to Article 17 (Artistes and Sportsmen). No updates relate to the OECD’s BEPS project.
An updated Model Tax Convention will be published in next few months. See, 2014 Update to the Model Tax Convention, Release.
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OECD releases report assessing the practices of 56 tax administrations
The 384-page OECD report, released August 11, compares tax administrations on their performance and discusses best practices and trends. See: OECD
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OECD releases model legislation, competent authority agreements to implement country-by-country reporting
The OECD on June 8 released model domestic legislation and competent authority agreements to implement the transfer pricing country-by-country (CbC) reporting plan developed under the OECD/G20 base erosion profit shifting (BEPS) project. The work furthers action 13 of the OECD/G20 BEPS plan and . . .
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OECD releases BEPS discussion draft on preventing artificial avoidance of PE status
The OECD on October 31 released a discussion draft on the artificial avoidance of permanent establishment ( PE) status, addressing commissionaire structures, the avoidance of PE status through specific activity exemptions, and other issues. The draft responds to Action 7 of the OECD/G-20 Action Plan on Base Erosion and Profit Shifting (BEPS), issued
. . .
UPDATE: OECD to hold January 21 consultation on draft rules to stop avoidance of PE status: Requests to attend or speak are due January 9.
Multinational
OECD set to release seven BEPS action plan items on September 16
The OECD has announced that it will publish its first set of deliverables under the OECD/G20 Base Erosion and Profit Shifting (BEPS) action plan on Sept. 16, and that it will hold a technical conference on the release the same day, streamed live on the internet. . .
Multinational
OECD seeks feedback on use of tax incentives by poor countries
The OECD on July 9 launched consultation on a draft paper offering guidance to low income countries on the use of tax incentives for investment. The consultation responds to a G20 Development Working Group’s. . .
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OECD releases revised BEPS discussion draft on avoidance of PE status
The OECD on May 15 released a revised discussion draft under action 7 of the OECD/G20 base erosion profit shifting (BEPS) action plan concerning artificial avoidance of permanent establishment (PE) status. The draft, prepared by Working Party No. 1 (WP1) of the. . .
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OECD releases global standard for automatic exchange of tax information
The OECD, on July 21, released the full version of its standard for automatic exchange of tax information. Included is an overview of the standard, the full text of the Model Competent Authority Agreement and the Common Reporting and Due Diligence Standard, commentaries on the model agreements, and seven annexes, including model multilateral and nonreciprocal competent . . .
Multinational
Breaking BEPS: The New International Tax Diplomacy – Itai Grinberg / SSRN
Professor Itai Grinberg of Georgetown University Law Center predicts that the parts of the BEPS plan to be implemented by the OECD Model Treaty will be implemented, whereas “everything else is subject to substantial doubt.” See: SSRN
Americas
US disappointed with BEPS plan guidance, Treasury officials say
The US is disappointed with much of the OECD/G20 base erosion profit shifting (BEPS) plan output, particularly work on permanent establishments (PEs), though it supports efforts on country-by-county reporting, dispute resolution, hybrids, and interest stripping, US Treasury officials said June 10–11 in Washington at the 2015 OECD International . . .
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Business reps critical of BEPS proposal to limit interest deductions through a group-wide test
In comment letters released February 11, business representatives argued that the OECD should not adopt a proposal to limit MNE interest deductions using a group-wide test, as proposed in a discussion draft released under OECD base erosion and profit shifting (BEPS) plan. Just over 100 comment letters were released in response to the discussion draft, issued December 18 . . .
Americas
Stack provides update of US position on BEPS
The Rascon CPA Firm has provided a report of October 3 comments made by Robert Stack, Treasury deputy assistant secretary (International Tax Affairs) concerning the OECD’s base erosion . . .
Europe
Multinational
OECD publishes abstracts of 11 forthcoming final BEPS reports, offering a glimpse of what’s inside
The OECD has published entries in its online library for the 13 final reports to be delivered under the OECD/G20 base erosion profit shifting (BEPS) plan, adding summaries of 11 reports that reveal some of the content of the coming . . .
Africa
G20 finance ministers endorse plan for multilateral instrument to implement BEPS
G20 finance ministers have agreed to a plan to create a multilateral instrument to implement tax treaty-related measures under OECD/G20 the base erosion and profit shifting (BEPS) plan, the ministers said in a communique following their February 9-10 meeting in Istanbul . . .
Asia-Pacific
China and Monaco sign agreement to prepare for automatic exchange of information
China and Monaco have signed the multilateral competent authority agreement, moving the countries one step closer to adopting automatic exchange of financial account information for tax purposes . . .
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Final OECD transfer pricing guidelines to revise draft’s treatment of risk, official says
The final version of the rewrite of Chapter 1 of the OECD Transfer Pricing Guidelines concerning delineation of transactions, risk, recharacterization, and special measures will be “quite different” from draft guidance on the topic released last December, Joe Andrus, consultant and former head of the transfer pricing unit at the OECD, said . . .
Multinational
OECD releases 20 comments to discussion draft on improving analysis of BEPS
The OECD on May 13 released comments to a discussion draft under action 11 of the base erosion and profit shifting (BEPS) plan on improving the availability and analysis of data on BEPS and on monitoring the effectiveness and economic impact of actions . . .
Asia-Pacific
Australia and UK push for coordinated action to stop MNEs from diverting profits
Australia and the UK have asked G20 nations to join them in an effort to stop the diversion of profits by multinational enterprises, in an initiative designed to go “further and faster” than the OECD’s base erosion and profit shifting (BEPS) plan, Australia’s . . .
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OECD releases BEPS draft on CFC taxation
The OECD on April 3 released a discussion draft that provides recommendations on how countries can design effective controlled foreign companies (CFC) rules to combat base erosion and profit shifting (BEPS). Released in response to action 3 of . . .
Multinational
OECD releases comments to transfer pricing discussion drafts
The OECD on February 10 released public comments to three discussion drafts that propose to modify OECD transfer pricing guidelines in response to the OECD/G-20 base erosion profit shifting (BEPS) plan. Eight-three public comments were released . . .
Multinational
OECD publishes seven BEPS action plan items
The OECD on Sept. 16 published its first set of deliverables under the OECD/G20 Base Erosion and Profit Shifting (BEPS) action plan along with an official Explanatory Statement
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