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 . . .
Professor Gabriel Zucman of UC Berkley, in his book, The Hidden Wealth of Nations, concludes that corporate and individual use of tax havens is increasing rapidly. See: Gabriel Zucman. Reviews: The Wall Street Journal, Bloomberg, Huffington Post.
The OCED announced May 28 that over 80 countries have agreed to participate in the development of a multilateral instrument to implement the OECD’s base erosion and profit shifting (BEPS) initiative. Work on the multilateral instrument has already commenced . . .
Two Canadian-U.S. dual citizens, on August 11, filed suit in the Federal Court of Canada challenging the constitutionality of the intergovernmental agreement signed by the U.S. and Canada that implements FATCA.
The lawsuit, funded by the Alliance for the Defense of Canadian Sovereignty (ADCS), alleges that the intergovernmental agreement violates provisions of the Canadian Charter of Rights and Freedoms . . .
The authors, both professors at Vienna University of Economics and Business, interviewed 61 Austrian tax experts, asking them to identify which OECD/G20 BEPS actions they believed would be most effective in combating multinational tax avoidance. See: SSRN
The OECD on July 7 released a model protocol to tax information exchange agreements to be used by governments wishing to extend . . .
G7 leaders, in a joint declaration issued June 8, made a “commitment to establish binding mandatory arbitration to ensure that the risk of double taxation does not act as a barrier to cross-border trade and investment.” The leaders also said they support work being done on binding arbitration as part of the OECD/G20 base erosion profit shifting (BEPS) project, and encouraged others . . .
UPDATE (6/9/2015): Christian Aid sounds alarm over G7 plan for mandatory tax arbitration: Christian Aid, on June 9, called the G7 leaders’ expression of support for compulsory binding arbitration in multinational tax disputes “deeply troubling,” stating . . .
The UK’s HM Revenue and Customs on May 21 issued guidance on the treatment of holding companies and treasury companies under FATCA, the multilateral competent authority agreement implementing the common reporting standard, and the . . .
Government and OECD tax officials at a February 17 OECD hearing suggested that, contrary to business representative assertions, a 30 percent of EBITDA fixed ratio is too high to effectively combat excessive multinational corporation interest deductions. Officials suggested that a lower percentage is appropriate for guidance on interest deductions being drafted under the OECD/G-20 base erosion and profit shifting (BEPS) plan. The day-long hearing concerned draft BEPS guidance under action 4, released December 18, that would limit . . .
An advance pricing agreement (APA) issued to Amazon by the Luxembourg tax authorities setting the price of intra-group royalties seems to be designed to ensure a predictable level of profit to Amazon’s Luxembourg operations rather than to achieve an arm’s length result, and thus appears likely to be state aid, the European Commission . . .
Ireland will close the “double Irish” corporate tax loophole beginning January 1, 2015, by requiring all companies registered in Ireland after that date to also be tax resident, the Irish government has announced.
Multinational firms with existing arrangements in Ireland will be able to use transition rules that will allow them to continue to use the loophole until the end . . .
OECD and G20 country tax officials have agreed that minimum standards should be added to tax treaties to prevent treaty shopping; have decided on the content required for transfer pricing documentation, including country-by-country reporting; and have narrowed the scope of hybrid mismatch proposals, OECD officials said during a Sept 16 OECD webinar introducing the first seven OECD base erosion profit shifting (BEPS) deliverables.
The OECD guidance, released as part of . . .
The OECD, on Sept. 1, released a condensed version of the 2014 Model Tax Convention on Income and Capital.
The document includes the text of the articles of the Model as they read on July 15, 2014, after the ninth update by the Council of the OECD. Also included is an introduction, commentaries to the articles, and the positions of non-member countries. 2014 Model Tax Convention, prior coverage
Ireland’s Department of Finance, on May 27, announced a consultation to consider international stakeholder’s views on how Ireland’s tax system should respond to the OECD’s base erosion and profit shifting (BEPS) initiative.
“Ireland remains 100% committed to the 12.5% corporation tax rate.
See also, Why Ireland should address corporate tax residency rules before we’re forced to, By Feargal O’Rourke, The Irish Times
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