Israel became the 91st signatory of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters on November 24, the OECD . . .
Mauritius on June 23 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the OECD has announced. The country is the 87th signatory to the . . .
The UK’s HM Treasury announced on October 6 that the UK government intends to propose rules to address hybrid mismatch arrangements consistent OCED/G20 base erosion profit shifting (BEPS) plan guidance on the topic.
The government will publish a consultation on . . .
The OECD on March 11 released a paper on the availability of transfer pricing comparability data for developing countries. The paper was prepared in response to a request by the G8 at its Lough Erne summit, “to find ways to address the concerns expressed by developing countries on the quality and availability of the information on comparable transactions that is needed to administer transfer pricing effectively.” Press Release, Paper
The OECD will provide effective mechanisms to resolve cross-border double taxation disputes in guidance under the OECD/G20 base erosion profit shifting (BEPS) plan, including mandatory and binding arbitration for those countries willing to adopt it, an OECD official said June 8 during an update of the OECD’s progress . . .
The Netherlands State Secretary of Finance on December 1 expressed support for a UK/German agreement to put limits on preferential intellectual property tax regimes under the OECD/G-20 base erosion profit shifting plan, but said that incentives should not be limited to activities that are legally protected, such as by patent, writes EY in a December 5 tax alert. The Netherlands does not plan major revisions to its innovation box regime, EY reported. For discussion, See EY.
In a surprising development, the US Senate Committee on Foreign Relations on November 10 approved without amendment proposed income tax treaties with Chile, Hungary, and Poland; proposed tax protocols with Japan, Luxembourg, Spain, and Switzerland; and a proposed protocol amending the multilateral mutual administrative assistance treaty. . .
About 100 EY firms have contributed to an August report on how the OECD/G20 base erosion profit shifting (BEPS) plan transfer pricing guidelines and documentation rules are being implemented throughout the world. See: EY .
The OECD has released a guide for its Tax Inspectors Without Borders (TIWB) initiative, a program which recruits currently serving or recently retired tax officials to work alongside tax officials in developing nations on international tax audits and audit-related . . .
The UK and Germany have agreed to a joint proposal on harmful tax practices which limits the patent box tax break, writes Reuters, quoting unnamed German government officials. The countries will present the proposal to the OECD Forum on Harmful Tax Practices. For details, see Reuters.
Witnesses testifying before the US Senate Committee on Foreign Relations on October 29 urged the committee to recommend ratification of eight pending US tax treaties and protocols, highlighting key aspects of the . . .
Tax officials at a June 6 OECD consultation suggested that draft guidance on cost contribution arrangements (CCAs) will be modified to clarify how to value CCA contributions. Officials also requested stakeholder feedback to help refine aspects of draft guidance on transfer pricing for hard-to-value . . .
The OECD’s planned guidance on the profit split method will likely consist of a series of examples that demonstrate when the method is considered the best method for transfer pricing purposes and how it should be . . .
Draft OECD guidance on hard-to-value intangibles released June 4 would permit tax administrations to consider ex post evidence of the actual financial outcome of a transfer of intangibles to determine the appropriateness of the ex ante pricing arrangement, including whether arm’s length parties would have used contingent pricing . . .
The OECD on June 1 released submissions from 45 organizations commenting on proposed revisions to the OECD transfer pricing guidelines dealing with cost contribution. . .
Monaco on October 13 because the 84th jurisdiction to sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Release.
The G-20 finance ministers have endorsed the final reports responding to the OECD/G20 base erosion profit shifting (BEPS) plan . . .
OECD tax officials have expressed dissatisfaction with a blacklist of 30 tax havens prepared by the European Commission, as have several countries on the list . . .
G20 leaders have endorsed the global common standard for automatic exchange of tax information and approve of progress made on the G20/OECD base erosion and profit shifting (BEPS) action plan, according to a communiqué released November 16, following a summit in Brisbane, Australia. The leaders said they are committed to . . .
Tax authorities from 51 jurisdictions have signed a multilateral competent authority agreement, laying the groundwork for automatic exchange of financial account information under the OECD/G-20 Common Reporting Standard beginning 2017 . . .
Tax officials from 38 countries pledged to increase their cooperation and collaboration to better handle the increased workload associated with implementing OECD/G-20 base erosion profit shifting (BEPS) . . .
The latest draft of the rewrite of Chapter 1 of the OECD Transfer Pricing Guidelines includes a new framework for analyzing risk that will address cash box companies without resort to any special measures, OECD tax officials said during a July 7 OECD consultation. Officials also provided a detailed update of other transfer pricing work being developed . . .
The OECD, in a discussion draft released December 16, announced that it is working on revising OECD transfer pricing guidelines relating to the use of the transactional profit split method and has requested feedback on issues associated with that project. . .
EY has published the transcript an interview with Pascal Saint-Amans, director of the OECD’s Center of Tax Policy and Administration, addressing the OECD’s Base Erosion Profit Shifting (BEPS) project, conducted by Alf Capito, EY’s Asia-Pacific tax policy leader. See, EY.
The OECD released the final base erosion profit shifting (BEPS) reports this morning. The 13 reports are based on the BEPS action plan, endorsed by the G20 in July 2013, which identified 15 key areas. . .
US Senate Finance Committee Chairman Orrin Hatch (R-UT) and House Ways and Means Chairman Paul Ryan (R-WI) today sent a letter to Treasury Secretary Jack Lew raising concerns about transfer pricing documentation requirements in the OECD/G20 base erosion and profit shifting (BEPS) plan and calling on the administration to consult . . .
The OECD on April 29 released a discussion draft proposing revisions to the OECD transfer pricing guidelines relating to cost contribution arrangements (CCAs) entered into between related parties. The proposal, which would modify Chapter VIII of the OCED transfer pricing guidelines, was released in response to action 8 of the OECD/G20 base erosion and. . .
The International Centre for Tax and Development (ICTD) has announced that it has established a research project to assist developing nations with OECD and IMF international tax reform initiatives.
The project will produce a series of briefing papers that will evaluate OECD and IMF proposals and devise specific recommendations for tax laws, regulations, and administrative practices. Project leaders are . . .
The OECD has published in one document all the executive summaries of all the final base erosion profit shifting plan reports. See: OECD.
Tax officials at a March 19 consultation on draft revisions to OECD transfer pricing guidelines expressed interest in adopting a special measure proposed in the draft that would address hard-to-value intangibles. Officials also discussed the weight that should be accorded a related party . . .
Bermuda is seeking immediate removal the European Commission’s list of non-cooperative jurisdictions as both Latvia and Poland have now confirmed that they have taken Bermuda off their national tax blacklists. Poland and Latvia have contacted the European Commission to confirm Bermuda’s. . .
An OECD discussion draft released December 16 proposes to modify OECD transfer pricing guidelines to clarify that the arm’s length price for commodities can be determined by reference to a commodity’s quoted or publicly available prices. The guidance also sets the shipment date as the default pricing date. . . .
The OECD on Oct 1 released a revised timetable for stakeholder consultation in its base erosion profit shifting (BEPS) project. Revised timeline, release
The OECD has revised the dates when discussion drafts will be published and public consultations held in relation to the September 2014 BEPS outputs. OECD
The OECD has asked transfer pricing officers in multinational enterprises to participate in an online survey on transfer pricing comparability data . . .
The OECD on June 18 released 65 public comments on a discussion draft under the OECD/G20 base erosion profit shifting (BEPS) plan dealing with tax treaty abuse. The draft, prepared by Working Party 1 of the OECD’s Committee on Fiscal . . .
The OECD on December 18 released four more discussion drafts addressing aspects of the OECD/G20 base erosion and profit shifting (BEPS) action plan. The drafts concern the application of VAT/GST to business-to-consumer (B2C) supplies of services and intangibles, seek to limit BEPS through interest deductions, and propose ways to improve the mutual agreement procedure (MAP) dispute resolution process. . . .
The OECD has announced that it will present webcasts on October 5 on the contents of the final reports under the . . .
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