The OECD, on August 4, requested pubic comment on BEPS Action 11, regarding the establishment of methodologies to collect and analyze data on BEPS and the actions to address it. Comments should be submitted by September 19. Request for input
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. . .
The OECD has announced that it will hold a January 21, 2015, consultation on its discussion draft concerning preventing the artificial avoidance of permanent establishment (PE) status. The draft was released on October 31 in response to action 7 . . .
New on SSRN website: “Financial Derivatives in Corporate Tax Avoidance: A Conceptual Perspective,” by Michael P. Donohoe, University of Illinois at Urbana-Champaign – SSRN
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 has released a discussion draft on the Tax Challenges of the Digital Economy. OECD Discussion Draft (PDF 1.40 MB) ; OECD Press Release. Analysis: KPMG
The US government is trying to persuade the EU Commission that it is inappropriate to require EU States to recover “retroactive” tax from multinationals upon a finding that illegal State aid was provided through overly-generous private tax rulings, Robert Stack . . .
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 UN has released a draft, designed to serve as the basis of discussion at the UN’s Third Annual Conference on Financing for Development, which recommends that the UN Committee of Experts on International Cooperation on Tax Matters be upgraded to an intergovernmental committee. The Committee of Experts, currently a subsidiary body . . .
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. . .
European Parliament leaders on February 5 failed to endorse the establishment of a committee of inquiry to investigate EU states’ private tax ruling practices, announcing instead that a vote will be taken in the next full house to set up a more limited special committee to handle the . . .
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’s Committee on Fiscal Affairs has approved recommendations for base erosion and profit shifting (BEPS) action plan items due to be presented to G20 finance ministers in September, according to a July 3 press release issued by the New Zealand government. Release
A report, released by the European Commission on May 28, concludes that a special tax regime should not be adopted for the digital economy, rather modification of current VAT, corporate tax, and transfer pricing rules are needed to respond to the digitization of the economy.
The report, drafted by group of seven independent tax experts led by Victor Gaspar, Special Advisor to the Banco de Portugal, responds to
. . .
Download the public comments (PDF 5.6MB)
The OECD has published in one document all the executive summaries of all the final base erosion profit shifting plan reports. See: OECD.
The European Parliament’s Legal Affairs committee, on May 7, backed a draft law that would require large firms and public-interest entities to publicly report information on a country by country basis, with a goal of strengthening transparency of tax strategies . . .
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 . . .
The European Commission on February 18 announced that it will present a tax transparency package in March which will include a legislative proposal for the automatic exchange of information on tax . . .
The OECD has published 77 comments received in response to its draft on preventing treaty abuse, which is Action 6 of the base erosion profit shifting initiative. Comments (PDF 6.59 MB)
Countries failed to agree to a proposal to upgrade the UN Committee of Experts on International Cooperation in Tax Matters to a more powerful UN intergovernmental body during the United Nations Third International . . .
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 European Court of Justice (ECJ), on April 10, ruled that Polish tax laws that exempt from withholding tax dividends paid to investment funds located in Poland and other EU countries, but that do not exempt dividends paid to funds located outside the EU, may be invalid because the laws restrict free movement of capital.
As a result, U.S. investment fund, Emerging Market Series of DFA Investment. . .
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 . . .
UK businesses must adjust their accounting for VAT on intragroup supplies of services beginning in 2016 to follow the European Court of Justice’s ruling in Skandia America, HMRC said in a policy briefing released February 10. . . .
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. . . .
A. Duane Webber will chair Baker & McKenzie’s Global Tax group, the firm announced at its annual meeting held October 7. Webber is based in Washington, DC. Release.
HM Treasury’s David Gauke on October 3 said the UK does not support the the adoption of the nexus approach described the OECD’s interim report on harmful tax practices to determine if intellectual property regimes reward “substantial activities” . . .
The European Commission, in a July 24 website post, announced it has extended the deadline for submitting applications to serve as a VAT Expert Group member until Sept. 12. Website, Call for Applications (22KB), Prior coverage.
The OECD has announced that it will present webcasts on October 5 on the contents of the final reports under the . . .
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 . . .
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