OECD releases further guidance for tax administrations and MNE Groups on Country-by-Country reporting (BEPS Action 13)
The Inclusive Framework on BEPS has released additional guidance to give certainty to tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) Reporting (BEPS Action 13), according to an announcement dated 30 November 2017 on the website of the OECD. The additional guidance addresses a number of specific issues: how to report amounts taken from financial statements prepared using fair value accounting; how to treat a negative figure for ...
OECD releases mutual agreement procedure (MAP) statistics for 2016
Improving the effectiveness and timeliness of dispute resolution mechanisms is the aim of Action 14 of the BEPS Action Plan (read the final report on Action 14 of the BEPS Action Plan) and is also part of the continuous efforts to enhance tax certainty. One of the elements of the Action 14 minimum standard requires jurisdictions to seek to resolve mutual agreement procedure ("MAP") cases within an average timeframe of ...
OECD delivers implementation guidance for collection of value-added taxes (VAT/GST) on cross-border sales
On 24 October 2017, the OECD released new implementation guidance to promote the effective collection of consumption taxes on cross-border sales. This guidance will support the consistent implementation of internationally agreed standards for the VAT treatment of cross-border trade and is of particular relevance given the rapid and ongoing digitalisation of the economy. The new guidance - Mechanisms for the Effective Collection of VAT/GST Where the Supplier Is Not Located ...
Curaçao regimes of the tax exempt entity, the export facility, and the E-zone mentioned in the 2017 Progress Report on Preferential Regimes as in the process of being amended
On 16 October 2017 the report “Harmful Tax Practices - 2017 Progress Report on Preferential Regimes, Inclusive Framework on BEPS: Action 5” was released by the OECD. This report provides details on the outcome of peer reviews undertaken of 164 preferential tax regimes identified amongst the more than 100 jurisdictions participating in the OECD Inclusive Framework on BEPS. See the separate item in today’s CFN regarding said report: “Harmful Tax Practices ...
Harmful Tax Practices – 2017 Progress Report on Preferential Regimes released
Governments have dismantled, or are in the process of amending, nearly 100 preferential tax regimes as part of the OECD/G20 BEPS standards to improve the international tax framework, according to a progress report released by the OECD/Inclusive Framework on 16 October 2017. The report “Harmful Tax Practices - 2017 Progress Report on Preferential Regimes, Inclusive Framework on BEPS: Action 5” provides details on the outcome of peer reviews undertaken of ...
BEPS Action 13: OECD releases CbC reporting implementation status and exchange relationships between tax administrations
On 11 October 2017, the OECD announced that a further step was taken to implement Country-by-Country Reporting in accordance with the BEPS Action 13 minimum standard, through activations of automatic exchange relationships under the Multilateral Competent Authority Agreement on the Exchange of CbC Reports ("the CbC MCAA"). Over 1000 automatic exchange relationships have now been established among jurisdictions committed to exchanging CbC Reports as of mid-2018, including those between EU Member States ...
Public comments received on BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits
On 22 June 2017, interested parties were invited by the OECD to provide comments on two discussion drafts. The first discussion draft on Attribution of Profits to Permanent Establishments, which deals with work in relation to Action 7 ("Preventing the Artificial Avoidance of Permanent Establishment Status") of the BEPS Action Plan; and a second one on Revised Guidance on Profit Splits, which deals with work in relation to Actions 8-10 ("Assure ...
OECD releases report Neutralising the tax effects of branch mismatch arrangements (BEPS Action 2)
On 27 July 2017 the OECD released a report Neutralising the tax effects of branch mismatch arrangements (BEPS Action 2). This report sets out recommendations for domestic rules that put an end to the use of hybrid entities to generate multiple deductions for a single expense or deductions without corresponding taxation of the same payment. For more information, click here. CFN-artikelnr. 20170728-8 BRONDOCUMENT BRON: www.oecd.org Land/gebiedsdeel: OECD Betreft: OECD, branch ...
Public comments received on the BEPS discussion draft on the Implementation Guidance to Hard-to-Value Intangibles
On 5 July 2017 the OECD published the public comments received on a discussion draft that provides guidance on the implementation of the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines. On 23 May 2017, interested parties were invited to provide comments on said discussion draft. CFN reported on said invitation in its edition of 26 May 2017, nr. 2017/17. CFN-artikelnr. 20170707-8 BRONDOCUMENT ...
Third meeting of the Inclusive Framework delivers results, according to OECD
Over 200 delegates from 83 countries and jurisdictions as well as 12 international and regional organisations met in Noordwijk, The Netherlands for the Third Meeting of the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), according to an announcement on the website of the OECD on 22 June 2017. The meeting , inter alia, discussed and approved its first monitoring report, which will be submitted to G20 Leaders for ...
OECD releases BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits
On 22 June 2017 the OECD has released the following discussion drafts: - Attribution of Profits to Permanent Establishments, which deals with work in relation to Action 7 ("Preventing the Artificial Avoidance of Permanent Establishment Status") of the BEPS Action Plan; - Revised Guidance on Profit Splits, which deals with work in relation to Actions 8-10 ("Assure that transfer pricing outcomes are in line with value creation") of the ...
OECD announces ground-breaking multilateral BEPS convention signed will close loopholes in thousands of tax treaties worldwide
On 7 June 2017 Ministers and high-level officials from 76 countries and jurisdictions have signed or formally expressed their intention to sign an innovative multilateral convention that will swiftly implement a series of tax treaty measures to update the existing network of bilateral tax treaties and reduce opportunities for tax avoidance by multinational enterprises. The new convention will also strengthen provisions to resolve treaty disputes, including through mandatory binding arbitration, thereby ...
OECD releases peer review document for assessment of the BEPS Action 6 minimum standard
On 29 May 2017 the OECD released the key document “BEPS Action 6 on Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, May 2017”, approved by the Inclusive Framework on BEPS, which will form the basis of the peer review of the Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances. For more information on this document, click here. CFN-artikelnr. 20170602-5 BRONDOCUMENT BRON: www.oecd.org ...
OECD releases a discussion draft on the implementation guidance on hard-to-value intangibles
On 23 May 2017 the OECD released a discussion draft on the implementation guidance on hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines and invites public comments. For more information, click here. CFN-artikelnr. 20170526-9 BRON: www.oecd.org Land/gebiedsdeel: OECD Betreft: Internationaal belastingrecht, implementation guidance, discussion draft, hard-to-value-intangibles, transfer pricing, TP, Transfer Pricing Guidelines, BEPS, Base Erosion and Profit Shifting, BEPS Action 8 Regeling: OECD discussion draft dated ...
