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 . . .
The World Customs Organization (WCO) has a published a guide for customs officials designed to move the debate forward on the issue of the harmonization of customs valuation and transfer pricing valuation.The guide . . .
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 UN Subcommittee on Base Erosion and Profit Shifting (BEPS), on July 8, extended the deadline for developing countries to respond to a questionnaire on BEPS.
The subcommittee, established by the UN Committee of Experts . . .
The OECD’s Working Party 6 has tentatively decided on a number of modifications to the OECD’s discussion draft on transfer pricing documentation and country-by-country reporting, including the elimination of entity-by-entity reporting in favor of country-level reporting, said Joseph Andrus, head of OECD transfer pricing , on April 2 during a webcast updating the base erosion and profit shifting (BEPS) initiative. Pascal Saint Amans, the OECD’s director of tax work, said that BEPS deliverables were “on track” for 2014 and that work has already begun on 2015 deliverables. . .
The EU Parliament on November 25 overwhelmingly approved wide-ranging proposals to overhaul Europe’s international tax system offered by a special Parliament committee investigating multinational . . .
UPDATE (11/26/2015): EU Parliament to establish new committee on tax rulings: The EU Conference of Presidents on November 26 decided to set up a six-month committee to follow up on the tax rulings committee’s work; the precise mandate of the new committee will be decided on Wednesday. See: Release.
UPDATE (12/02/2015): New EU Parliament tax committee will have same mandate as its predecessor: The European Parliament on December 2 voted to create a new committee to investigate tax rulings, specifying that the new committee will have the . . .
India’s Competent Authority Akhilesh Ranjan discusses mandatory arbitration, country-by-country reporting, other BEPS topics with Mukesh Bhutani of BMR Advisors and Arun Giri of Taxsutra in a report published in The Firm on September 7. See: The Firm.
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 European Commission has been forced to delay decisions on whether countries violated state aid rules by granting private tax rulings to Amazon, Apple, Fiat, and Starbucks, EU competition commissioner, Margrethe Vestager, said May 5 . . .
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 . . .
German, French, and Italian finance ministers have asked the EU Commission to take immediate steps to more aggressively tackle corporate tax avoidance in the EU. In a letter addressed to European economy, finance and tax commissioner Pierre Moscovici . . .
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 . . .
European Commission President Jean Claude Juncker on November 12 said advance tax rulings issued by Luxembourg to multinationals while he was the country’s prime minister were legal even though the rulings helped multinationals avoid tax due other European nations. Juncker was responding the uproar over the release of leaked taxpayer private rulings and tax returns which were . . .
The European Court of Justice (ECJ), on June 12, ruled in SCA Group Holding BV and other joined cases that the Netherlands may not deny single entity tax treatment to a resident parent company and its indirectly held Dutch subsidiary (sub-subsidiary) in cases where the sub-subsidiary’s parent is a not a Dutch . . .
-For implications of the ECJ opinion on Spain’s rules governing tax consolidation, see a June 17 report by EY
Staff of the OECD, UN, IMF, and World Bank on November 6 released a report Options for Low Incomes Countries’ Effective and Efficient Use of Tax Incentives for Investment. The report was prepared at the request of the G20 Development Working Group. See: Report.
The European Commission on June 8 escalated its inquiry into whether EU countries’ tax ruling practices provide a selective advantage to companies in violation of state aid rules, asking 15 EU nations to provide the . . .
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 EU Joint Transfer Pricing Forum (JTPF) has proposed modifications to the EU Arbitration Convention and revised Code of Conduct to better accommodate transfer pricing disputes. in a report released on its website, the JTPF . . .
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 . . .