Multinational
Multinational
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G20 finance ministers consider tax implications of digitalization, tax certainty
G20 finance ministers and central bank governors, in a communique following their March 17–18 meeting in Baden-Baden, Germany, called on an OECD task force to produce an interim . . .
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OECD draft examples address tax treaty “principal purpose test” for non-CIV funds
The OECD has today released for public comment three draft examples addressing the application of the OECD/G20 base erosion profit shifting (BEPS) Action 6 principal purpose test to . . .
Europe
EU Commission to draft financial transaction tax legislation
The EU Commission has been asked to prepare draft legislation for a financial transaction tax (FTT) following significant progress made on the design of the tax . . .
Multinational
Americas
Tax officials preview coming OECD guidance on profit splits, attribution of profits to PEs
Tax officials provided an update of international tax and transfer pricing guidance currently being developed at the OECD, including work on profit splits and on attribution of profits to permanent establishments (PEs), at Washington DC conference sponsored by the OECD, USCIB, and . . .
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IMF, OECD, UN, and Word Bank Group to jointly work on multinational business tax issues
The International Monetary Fund, OECD, United Nations, and World Bank Group today released a concept note outlining their plan to work together to help governments address the tax policy . . .
Americas
Digital Economy
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Multinational
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Tax officials preview coming OECD transfer pricing guidelines on financial transactions
Draft OECD transfer pricing guidelines on related party financial transactions, slated for release this summer, will include important guidance for multinationals on intercompany loans, cash pooling, and reinsurance, though reaching consensus among countries on some fundamental issues is . . .
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Draft OECD transfer pricing guidance released on hard-to-value intangibles
The OECD today released a discussion draft providing guidance to tax administrations on how to implement transfer pricing guidelines on transfers of hard-to-value intangibles. An approach to hard-to-value . . .
Multinational
Multinational
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OECD publishes updated manual on preventing BEPS through interest deduction limits
The OECD on December 22 published a report on limiting base erosion involving interest deductions and other financial payments, updating . . .
Asia-Pacific
India-Cyprus tax treaty renegotiated: key provisions
Mansi Seth, head of Nishith Desai Associates’ US practice, and Ashish Sodhani, a senior member of the firm’s international tax practice, discuss the renegotiated India-Cyprus tax treaty, which provides for source-based taxation of capital gains arising from alienation of shares . . .
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OECD surveys business about need for tax certainty
The OECD today invited business representatives to respond to a survey on how tax certainty promotes . . .
Europe
OECD finalizing BEPS multilateral instrument, concerned about EU state aid tax probes
Officials are putting the finishing touches on the multilateral instrument (MLI) to implement the OECD/G20 base erosion profit shifting (BEPS) measures, keeping it on track to be finalized this fall, senior . . .
Africa
Jamaica, Angola, Seychelles join BEPS effort to crack down on MNE tax avoidance
Jamaica, Angola, and Seychelles have joined the framework to implement the OECD/G20 base erosion profit shifting (BEPS) project to combat multinational tax avoidance, the . . .
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G7 leaders pledge to steadily adopt BEPS international tax measures
Leaders of the G-7 nations of the US, UK, Canada, France, Japan, Germany, and Italy, following their meeting in Ise-Shima, Japan, vowed to “lead by example” by implementing the OECD/G20 base erosion profit shifting (BEPS) package in . . .
Europe
Multinational
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G20 finance ministers endorse OECD plan to open BEPS project to all countries
G20 finance ministers, during their February 26–27 meeting in Shanghai, approved an OECD-developed plan to allow all countries to participate in the implementation of base erosion profit shifting (BEPS) . . .
Africa
Europe
Americas
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OECD lists countries agreeing to country-by-country reporting exchange
The OECD today released an updated list of automatic exchange relationships established between tax authorities to implement country-by-country reporting under Action 13 of the OECD/G20 base erosion profit shifting (BEPS) plan. The OECD also announced activation of automatic . . .
Europe
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New UN extractives industry guidance note analyzes value chain for mining, oil and gas
US transfer pricing lawyers Robert Feinschreiber & Margaret Kent examine a guidance note, released last week by the UN’s Committee of Experts on International Cooperation in Tax Matters, which concerns transfer pricing issues associated with extractive industries, specifically mining and mineral extraction and oil and natural gas production . . .
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World Bank publishes transfer pricing handbook for developing countries
Joel Cooper of DLA Piper discusses a new World Bank handbook designed to assist developing country tax administrations with the implementation of transfer pricing rules. . .
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OECD releases discussion drafts on attribution of MNE profits to permanent establishments and profit splits
The OECD today released two discussion drafts on international tax standards that deal with allocating multinational corporation profits between tax jurisdictions: guidance on the attribution of profits to permanent establishments (PEs) and proposed revisions to guidance on profit splits under the OECD . . .
Austria
EU finance ministers split on public release of multinational corporation tax data
Dutch finance minister and president of the Eurogroup, Jeroen Dijsselbloem, expressed support for a proposal that would mandate public release of country-by-country tax data on multinationals, while finance ministers from Malta, Belgium, and Austria . . .
Australia
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .
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Part two: international tax consultation on “digitalization” draws 50 speakers (pillar two)
Part two of two. This article summarizes discussion of the “pillar two” proposals at the OECD digitalization consultation, held March 13–14 in Paris. The pillar two proposals, described in a February 13 OECD discussion draft, call for global adoption of a minimum tax and a tax on base eroding payments. . . .
Digital Economy
Digital Economy
