The OECD today released guidance for low tax countries on standards for exchanging information with other countries to meet standards set by a coalition of 120+countries known as the “Inclusive Framework on BEPS.”
These standards, set out in a November 15, 2018 report, a require no and low tax countries, namely, tax havens, to exchange information about businesses that generate mobile income and that fail to meet a “substantial activities” requirement with the jurisdiction of residence of the immediate parent, ultimate parent, and ultimate beneficial owner.
Generally, such mobile activities include headquarters, distribution centers, service centers, financing, leasing, fund management, banking, insurance, shipping, holding companies, and provision of intangibles. .
The guidance released today sets out the practical modalities regarding the exchange of information requirements of the Inclusive Framework standard.
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