Kamerbrief staatssecretaris over ontwikkelingen rondom Pijler 1: door recente ontwikkelingen kan op dit moment geen MLC ondertekend worden (Nederland)
In een brief d.d. 20 oktober 2023 informeert de Nederlandse staatssecretaris van Financiën (Fiscaliteit en Belastingdienst) over de meest recente ontwikkelingen rondom Pijler 1. Hieronder volgen enkele indicatieve frases uit de kamerbrief (enigszins geparafraseerd). De afgelopen jaren is binnen het Inclusive Framework (IF) georganiseerd door de Organisatie voor Economische Samenwerking en Ontwikkeling (OESO) gewerkt aan een herziening van het internationale belastingsysteem, omdat de vraag opkwam of de huidige internationale regels ...
OECD/G20 Inclusive Framework releases new Multilateral Convention to Implement Amount A of Pillar One addressing tax challenges of globalisation and digitalisation
The OECD/G20 Inclusive Framework on BEPS has released the text of a new multilateral convention (MLC) that updates the international tax framework to co-ordinate a reallocation of taxing rights to market jurisdictions, improve tax certainty, and remove digital service taxes. The publication of the convention moves the international community a step closer towards finalisation of the Two-Pillar Solution to address the tax challenges arising from the digitalisation and globalisation of ...
International community adopts multilateral convention to facilitate implementation of the global minimum tax Subject to Tax Rule
The OECD/G20 Inclusive Framework on BEPS has concluded negotiations on a multilateral instrument that will protect the right of developing countries to ensure multinational enterprises pay a minimum level of tax on a broad range of cross-border intra-group payments, including for services. This has been announced in a news release on the website of the OECD. The new Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax ...
Sixth annual peer review report of BEPS Action 13: ‘Progress continues in strengthening tax transparency through Country-by-Country reporting’
The OECD has published the sixth annual peer review report of BEPS Action 13 (Country-by-Country reporting). The peer review report contains the latest outcomes of the implementation of BEPS Action 13 on the transparency of global operations of large MNEs, ‘demonstrating strong progress in international efforts’ according to a news release on the website of the OECD issued on the occasion of the release of the report. Further form the ...
Sixth annual peer review report BEPS Action 13 (Country-by-Country reporting): recommendation for Curaçao to take steps to ensure that the number of CbC reports received and exchanged are monitored (Curaçao)
The OECD has published the sixth annual peer review report of BEPS Action 13 (Country-by-Country reporting). The peer review report contains the latest outcomes of the implementation of BEPS Action 13 on the transparency of global operations of large MNEs. Click here for a link to the news release on the website of the OECD issued on the occasion of the release of the report. The BEPS Action 13 minimum standard ...
Sixth annual peer review report BEPS Action 13 (Country-by-Country reporting): no recommendations for Aruba as to the domestic legal and administrative framework or the exchange of information framework (Aruba)
The OECD has published the sixth annual peer review report of BEPS Action 13 (Country-by-Country reporting). The peer review report contains the latest outcomes of the implementation of BEPS Action 13 on the transparency of global operations of large MNEs. Click here for a link to the news release on the website of the OECD issued on the occasion of the release of the report. The BEPS Action 13 minimum standard ...
OECD releases the final batch of the stage 1 peer review reports for BEPS Action 14 on dispute resolution mechanisms
On 16 February 2021 the OECD released the final batch of the stage 1 peer review reports for BEPS Action 14 on dispute resolution mechanisms. The stage 1 peer review assessments for Aruba, Bahrain, Barbados, Gibraltar, Greenland, Kazakhstan, Oman, Qatar, Saint Kitts and Nevis, Thailand, Trinidad and Tobago, United Arab Emirates and Viet Nam evaluate the efforts made by each jurisdiction to implement the Action 14 minimum standard of the OECD/G20 BEPS Project, which aims to improve the resolution of tax-related disputes between jurisdictions ...
Stage 1 peer review report on dispute resolution released by OECD: overall Aruba meets the majority of the elements of the Action 14 Minimum Standard and where it has deficiencies, Aruba is working to address some of them
On 16 February 2021 the OECD released the final batch of the stage 1 peer review reports for BEPS Action 14 on dispute resolution mechanisms, including the stage 1 peer review assessment for Aruba. This has been announced by the OECD with a press release dated 16 February 2021 on the occasion of the release of the peer review reports. The reports evaluate the efforts made by each jurisdiction to implement ...
OECD releases new methodology for the peer review of BEPS Action 13
Yesterday, October 29th 2020, the OECD released the new methodology for the peer review of BEPS Action 13 Country-by-Country Reporting. This was announced by the OECD in a press release dated 29 October 2020 on the release of the report. Furthermore from the press release: The Action 13 standard on Country-by-Country Reporting is one of the four BEPS minimum standards. Each of the four BEPS minimum standards is subject to ...
Countries have responded decisively to the COVID-19 crisis, but face significant fiscal challenges ahead
Governments have taken unprecedented fiscal action in response to the COVID-19 crisis, but countries will need to support economic recovery in the face of significantly increasing fiscal challenges, according a new OECD report Tax Policy Reforms 2020: OECD and Selected Partner Economies. This was announced by the OECD in a press release dated 3 September 2020 on the release of the report. Tax Policy Reforms 2020 describes the latest tax ...
BEPS Action 14: OECD releases stage 1 peer review reports on dispute resolution for Brunei Darussalam, Curaçao, Guernsey, Isle of Man, Jersey, Monaco, San Marino and Serbia
The work on BEPS Action 14 continued with the publication on 24 February 2020 of the eighth round of stage 1 peer review reports. Each report assesses a country's efforts to implement the Action 14 minimum standard as agreed to under the OECD/G20 BEPS Project. This was announced with a press release published on the website of the OECD. From the press release: The reports of Brunei Darussalam, Curaçao, Guernsey, Isle of Man, Jersey, Monaco (also available ...
Stage 1 peer review report on dispute resolution released by OECD: overall Curaçao meets most of the elements of the BEPS Action 14 Minimum Standard
On 24 February 2020 the stage 1 peer review report for Curaçao on dispute resolution (BEPS Action 14) was released by the OECD: Making Dispute Resolution More Effective – MAP Peer Review Report, Curaçao (Stage 1): Inclusive Framework on BEPS: Action 14, OECD/G20 Base Erosion and Profit Shifting Project (hereafter to be referred to as: “the report”). The report assesses the country's efforts to implement the Action 14 minimum standard ...
OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors
On 14 February 2020, the OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors was released. From the overview in the report: “Over the past 10 years, the G20 has supported multilateral co-operation for a globally fair, sustainable and modern international tax system, which translated into successful deliverables. Thanks to this momentum, significant progress has taken place to combat tax evasion, Base Erosion and Profit Shifting (BEPS), ...
OECD presents analysis showing significant impact of proposed international tax reforms
New economic analysis shows that a proposed solution to the tax challenges arising from the digitalisation of the economy under negotiation at the OECD would have a significant positive impact on global tax revenues. This was announced in a press release published on the website of the OECD in relation to the release of the analysis. From the press release: The analysis puts the combined effect of the two-pillar solution under ...
OECD releases Transfer Pricing Guidance on Financial Transactions
On 11 February 2020, the OECD released the report Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10. This was announced in a press release published on the website of the OECD. In October 2015, as part of the final BEPS package, the OECD/G20 published the reports on Action 4 (Limiting Base Erosion Involving Interest Deductions And Other Financial Payments) and Actions 8-10 (Aligning Transfer Pricing Outcomes with ...
Uruguay deposits its instrument of ratification for the Multilateral BEPS Convention
On 6 February 2020, Uruguay deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Multilateral Convention or MLI) with the OECD's Secretary-General, Angel Gurría, thus underlining its strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting (BEPS) by multinational enterprises. For Uruguay, the MLI will enter into force on 1 June ...
OECD releases consultation document on the review of Country-by-Country Reporting and invites public input (BEPS Action 13)
As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework), the OECD invites public comments on the Review of the BEPS Action 13 minimum standard. This was announced in a press release published on the website of the OECD. From the press release: Background Action 13 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project (BEPS Action 13) established a three-tiered standardised approach to ...
International community renews commitment to multilateral efforts to address tax challenges from digitalisation of the economy
The international community reaffirmed its commitment to reach a consensus-based long-term solution to the tax challenges arising from the digitalisation of the economy, and will continue working toward an agreement by the end of 2020, according to the Statement by the Inclusive Framework on BEPS released by the OECD on January 31, 2020. This was announced in a press release published on the website of the OECD. From the press release: The ...
The Netherlands among first peer reviews on implementation of BEPS minimum standards on improving tax dispute resolution mechanisms. Treaty analysis also includes the tax arrangements with Curaçao and Sint Maarten
As we reported today in a separate article, the Netherlands is among the first six peer review reports on implementation of BEPS minimum standards on improving tax dispute resolution mechanisms which were released by the OECD on 26 September 2017. Interesting to learn for the Dutch Caribbean tax practice is that the treaty analysis in the peer review relating to the Netherlands also includes, as we understand, the “Tax Arrangement ...
OECD releases first peer reviews on implementation of BEPS minimum standards on improving tax dispute resolution mechanisms
On 26 September 2017, as part of continuing efforts to improve the international tax framework, the OECD has released the first analysis of individual country efforts to improve dispute resolution mechanisms. The six peer review reports represent the first evaluation of how countries are implementing new minimum standards agreed in the OECD/G20 BEPS Project. The first six peer review reports relate to implementation by Belgium, Canada, the Netherlands, Switzerland, the United ...