The OECD on June 19 released 42 public comments on a discussion draft on action 8 of the OECD/G20 base erosion profit shifting (BEPS) plan dealing with hard-to-value intangibles for purposes. . .
Christian Aid on June 9 called the G7 leaders support for mandatory binding arbitration for multinational tax disputes “deeply troubling,” stating that the mechanism could further harm poor countries . . .
The OECD on December 19 released a discussion draft proposing significant revisions to the OECD transfer pricing guidelines to address base erosion and profit shifting (BEPS). The draft seeks to provide a more accurate delineation of related party transactions, provides guidance on the relevance and allocation of risk, and provides for the recharacterization of transactions in some cases. The draft also sets out five “special measures,” including . . .
Ireland may not support a proposal advanced by the UK and Germany to use a modified nexus approach to put limits on preferential intellectual property tax regimes under the OECD/G-20 base erosion profit shifting (BEPS) plan, Finance Minister Michael Noonan said December 2. The joint UK/German proposal, announced by the . . .
The OECD on October 28 published comments received in response to its discussion draft, “Transfer Pricing Comparability Data and Developing Countries,” including an appeal by the World Bank Group to the OECD to develop guidance on the use of foreign comparables . . .
G20 finance ministers, in a communique released following their Sept. 20-21 meeting in Carins, Australia, have expressed approval of the progress made toward completion of the G20 OECD Base Erosion and Profit Shifting (BEPS) Action Plan and have committed to finalizing all action items by 2015. Further, the ministers endorsed the finalized global Common Reporting Standard for automatic exchange of tax information, committing to exchange of information by 2017 or end-2018, subject to the completion of legislative procedures. Communique. See also, G20 release, prior coverage of BEPS recommendations.
UK formally commits to country-by-country reporting template: The UK has agreed to implement the country-by-country reporting template provided for in the OECD/G20 BEPS recommendations, Financial Secretary to the Treasury David Gauke announced in a Sept. 20 release. See, UK release.
_____________
India disputes binding arbitration proposals in BEPS recommendations: In a Sept. 22 speech before the G20, India’s Minister of State for Finance expressed support for the OECD/G20 BEPS project but said that developing nations had “major concerns” with proposals to introduce binding arbitration into the mutual agreement procedure for tax treaties. See, speech of Smt. Nirmala Sitharaman, India Minister of State for Finance. See, related coverage.
_____________
The OECD and Global Forum announce mandate to assist developing nations with BEPS: The OECD and its Global Forum on Transparency and Exchange of Information announced on Sept. 22 that they have been mandated by the G20 to develop toolkits to support developing countries in addressing BEPS and to launch pilot projects to assist them to move towards automatic exchange of information. The OECD said it will report to the G20 Leaders in November on its plan to deepen the involvement of developing countries in the OECD/G20 BEPS project and ensure that their concerns are addressed. OECD release.
An OECD report, released August 1, identifies the main sources of base erosion and profit shifting (BEPS) in developing countries and the extent to which the OECD/G20 Action Plan addresses these concerns.
After interviewing developing nation officials. . .
Germany had the greatest number of unresolved mutual agreement procedure (MAP) cases among OECD countries during the 2014 reporting period, according to OECD statistics . . .
The OECD on January 20 published 65 comment letters on proposed amendments to the OECD transfer pricing guidelines that would provide for elective, simplified, rules for determining the amount of low value-adding intra-group services to be charged to and paid for by individual members of an MNE group. The draft, released November 3, 2014, responds . . .
An OECD discussion draft scheduled to be released this week includes a proposal to put limits on an MNE’s net interest deductions based on worldwide net third party interest expenses, OECD officials said December 15 during a webcast updating work on the OECD/G20 base erosion and profit shifting (BEPS) project. Officials also said that the OECD intends . . .
OECD and the United Nations Development Programme (UNDP) officials on July 13 formally announced the launch of the Tax Inspectors Without Borders program at the UN’s Third International Conference on Financing for Development held in Addis Ababa, Ethiopia. The new program recruits currently serving or recently retired . . .
Tax officials from 21 Asia Pacific countries and organizations attended an OECD regional network meeting on base erosion and profit shifting (BEPS) designed to give more nations a voice in the development of OECD/G20 base erosion profiting shifting (BEPS) plan output. The meeting, held February 12–13 in Seoul, also . . .
Countries can legally use a multilateral instrument to amend existing bilateral tax treaties to implement the OECD’s base erosion and profit shifting (BEPS) initiative, Pascal Saint-Amans, Director, OECD Center for Tax Policy and Administration, said on May 26, during an update of OECD progress on the BEPS action plan.
Saint-Amans said that a team of international lawyers have found legal precedent in areas other than tax . . .
G20 finance ministers and central bank governors, in a communique released following their September 5 meeting in Ankara, Turkey, called on the OECD to establish a framework by early 2016 on the implementation of OECD/G20 base erosion and profit shifting (BEPS) plan . . .
Update: See also: OECD Secretary-General Report To G20 Finance Ministers
Senior OECD officials defended draft changes to the OECD transfer pricing guidelines on risk, recharacterization, and special measures February 12, arguing that revisions to the guidelines are needed to strengthen the arm’s length principle and to properly align a transaction’s form with its substance. The discussion draft, released December 19, proposes significant . . .
The OECD on June 15 released public comments from 60 organizations on a revised discussion draft under action 7 of the OECD/G20 base erosion and profit shifting (BEPS) plan concerning artificial avoidance of permanent establishment (PE) status. The comments, numbering 319 pages, generally express . . .
The OECD on March 31 released a discussion draft under the OECD/G20 base erosion profit shifting (BEPS) plan providing recommendations to tax administrations on how to structure mandatory disclosure rules to address aggressive tax planning. Included are recommendations on how to deal with international . . .
A joint proposal advanced by the UK and Germany that put limits on preferential intellectual property regimes has been adopted by the OECD Forum on Harmful Tax Practices (FHTP) as a new starting point for drafting guidance under Action 5 the base erosion profit shifting (BEPS) plan, UK Financial Secretary to the Treasury, David Gauke said December 2. Gauke said the UK/German proposal . . .
The OECD on November 21 released a discussion draft under Action 6 of the OECD/G20 base erosion and profit shifting (BEPS) plan relating to preventing abuse of tax treaties. The draft follows up on an OECD interim report, issued September 16, which reflects an agreement among countries to require minimum standards in tax treaties to prevent treaty abuse. The report states that treaties should include either a principle . . .
The OECD on May 5 released public comments to an OECD discussion draft that provides recommendations on how countries can design effective controlled foreign companies (CFC) rules to combat base erosion and profit shifting (BEPS). Sixty-two comments were released in response to the guidance, issued April 3 in response to action 3 of the OECD/G20 BEPS. . .
The G20/OECD base erosion profit shifting (BEPS) project is in its “decisive stages,” with only six months remaining until the 15 BEPS deliverables must be completed, Angel Gurría Secretary-General of the OECD said at a meeting of World Bank Group and International Monetary Fund officials, G20 Finance Ministers, and Central Bank Governors held . . .
The OECD on January 12 released public comments to discussion drafts under the OECD’s base erosion and profit shifting (BEPS) action plan which deal with the prevention of tax treaty abuse and with the artificial avoidance of permanent establishment (PE) status. Eighty comments were released on the tax treaty . . .
The OECD will invite some developing nations to participate in OECD Committee on Fiscal Affairs (CFA) meetings, will hold regional consultations, and will work on capacity development in an effort to increase developing nation input in the OECD/G-20 base erosion profit shifting (BEPS) plan decision-making . . .
UPDATE: Philippines Joining OECD Committee on Fiscal Affairs: The Philippines will join the OECD Committee on Fiscal Affairs to work on a global response to BEPS beginning January 2015, the Philippines Department of Finance announced November 14. See, Philippines release.
Draft guidance released November 3 would modify the OECD transfer pricing guidelines to provide elective, simplified, transfer pricing rules for low value-adding intra-group services. The guidance was released in response to Action 10 of the OECD Base Erosion and Profit Shifting (BEPS) plan, which directs the OECD to develop transfer pricing rules or special measures “to provide protection against common types of base eroding . . .
Tax officials from 104 jurisdictions attending the November 5-6 meeting of the OECD’s Global Forum on VAT endorsed new OECD VAT/GST guidelines on the treatment of cross-border trade in services and intangibles and suggested that the OECD next consider taking on several new VAT . . .
Uganda on November 4 became the 90th signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the OECD has . . .
The OECD/G20 base erosion profit shifting (BEPS) project work should not be used to adopt protectionist measures, Josephine Teo, Singapore Minister of State for Finance and Transport . . .
Materials that accompany a UK draft law suggest that OECD/G20 base erosion profit shifting (BEPS) guidance will recommend that country-by-country reporting data be disseminated using a tax treaty mechanism, vastly limiting the scope of the reform, tax campaigners say . . .
The OECD on November 25 released 2013 statistics on the mutual agreement procedure (MAP) caseload of OECD member counties and partner economies of Argentina, China, Latvia, and South Africa. According to an accompanying OECD . . .
Finance ministers from the UK, France, Germany, Italy and Spain, on 28 April, agreed to sign new global standards of automatic exchange of tax information at the October Global Forum meeting in Berlin. The countries will begin to automatically exchange information in 2017, with respect to data collected from 31 December 31, 2015. UK Press Release, German Press Release, French Press Release
The OECD on April 4 released public comments on a discussion draft under action 12 the base erosion profit shifting (BEPS) plan dealing with mandatory disclosure rules. The draft guidance, issued March 31, provides recommendations to tax administrations on how to structure mandatory disclosure rules . . .
The OECD on April 16 released a draft report 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 taken to address BEPS. The report concludes that lack of data . . .
The OECD on February 24 released 47 comments to a discussion draft on OECD international VAT/GST guidelines relating to the place of taxation of business-to-consumer (B2C) supplies of services and intangibles. The draft, prepared under . . .
Germany and the UK have agreed to a proposal that would put limits on preferential intellectual property regimes, including the UK’s patent box regime, for purposes of drafting uniform rules responding to Action 5 of the OECD/G-20 base erosion profit shifting (BEPS) plan. The compromise proposal breaks . . .
The OECD on Oct. 7 published comments to Action 11 of its base erosion profits shifting (BEPS) initiative concerning the establishment of methodologies to collect and analyze data on BEPS and the actions to address it.
The OECD received 28 comments, including submissions from China and Costa Rica, prominent academics, trade associations, and advisers.
The comments were submitted in response to an August 4 OECD request for input.
Pascal Saint-Amans, the director of the OECD Centre for Tax Policy and Administration, addressed Ireland’s recent tax announcements and his views on whether the US will implement or block the OECD/G-20 base erosion profit shifting measures during an interview with the Irish Independent. See, Irish Independent.
Countries negotiating the OECD/G-20 base erosion profit shifting (BEPS) guidance have advanced a proposal to require countries that seek access to country-by-country reporting data to first to agree to enhanced dispute resolution, a US Treasury official said on Sept 17.
Speaking during a Deloitte webinar, Robert Stack, US Treasury Deputy . . .
Senior OECD officials provided an overview the 13 final reports issued under the OECD/G20 base erosion and profit shifting plan (BEPS) during two webcasts that aired October 5, just after the reports were released. Discussion covered all 15 action items, including . . .
Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.
