Peer review report assessing jurisdictions’ efforts to prevent tax treaty shopping (BEPS Action 6) – Aruba

On 1 April 2021, the OECD released the latest peer review report assessing jurisdictions' efforts to prevent tax treaty shopping and other forms of treaty abuse under Action 6 of the OECD/G20 BEPS Project: Prevention of Tax Treaty Abuse – Third Peer Review Report on Treaty Shopping (Inclusive Framework on BEPS: Action 6, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris). The release was announced with a press ...

OECD publishes 30 country profiles applying Arbitration under the multilateral BEPS Convention

On 25 March 2021, the OECD, in its capacity as Depositary of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI), has published the Arbitration Profiles of 30 jurisdictions applying Part VI on Arbitration of the MLI and an opinion of the Conference of the Parties to the MLI. This has been announced with a press release on the website of ...

Tax transparency moves forward as twelve no or only nominal tax jurisdictions began their first exchange information on the substance of entities

On Wednesday 31 March 2021, twelve no or only nominal tax jurisdictions began their first tax information exchanges under the Forum on Harmful Tax Practice’s (FHTP) global standard on substantial activities. The standard ensures that mobile business income can no longer be parked in a low tax jurisdiction without the core business functions being carried out from that jurisdiction and that the countries where the parent entities and beneficial owners ...

OECD presents international tax update to G20 Finance Ministers

On 26 February 2021, the OECD has published the “OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors – Italy February 2021”. Click here to go to the report on the website of the OECD. CFN-bericht nr. 20210305-13 BRONDOCUMENT (link to the report on the website of the OECD) Zie ook: CFN van 16 oktober 2020: OECD presents international tax update to G20 Finance Ministers. BRON: www.oecd.org ...

OECD agrees new peer review process to foster transparency on tax rulings

In order to maintain and further improve transparency on tax rulings, the OECD/G20 Inclusive Framework on BEPS, which groups over 135 countries and jurisdictions on an equal footing for multilateral negotiation of international tax rules, approved the process for the BEPS Action 5 peer review of the transparency framework for the years 2021 to 2025. This has been announced by the OECD with a press release dated 22 February 2021 ...

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 ...

Dominica added to the EU list of non-cooperative jurisdictions, Barbados removed

On 22 February 2021, the Council of the European Union (EU) adopted conclusions on the revised EU list of non-cooperative jurisdictions for tax purposes, deciding to add Dominica to the EU list of non-cooperative jurisdictions (Annex I of the conclusions) and to remove Barbados from that list. This has been announced with a press release dated 22 February 2021 on the website of the European Commission. Furthermore from the press ...

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 ...

Barbados deposits its instrument of ratification for the Multilateral BEPS Convention

On 21 December 2020, Barbados 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), which now covers over 1700 bilateral tax treaties, thus underlining its strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting (BEPS) by multinational enterprises. For Barbados, the MLI will enter into force on ...

Ontwerp Fiscale verzamelwet 2022 aangeboden aan de Tweede Kamer: onder meer een algemene antimisbruikmaatregel in de WIB naar aanleiding van een aanbeveling door het Global Forum in het kader van CRS (Nederland)

Op 18 januari 2021 is de ontwerpwet tot wijziging van enkele belastingwetten (Fiscale verzamelwet 2022) aangeboden aan de Tweede Kamer der Staten-Generaal. Klik hier voor een pdf van de Memorie van Toelichting (MvT) bij het ontwerp. In het ontwerp wordt onder meer voorzien in het opnemen van een algemene antimisbruikmaatregel in de Wet op de internationale bijstandsverlening bij de heffing van belastingen (WIB). De algemene antimisbruikmaatregel wordt opgenomen naar aanleiding ...

Public comments received on the Reports on Pillar One and Pillar Two Blueprints

As part of the ongoing work to develop a solution to the tax challenges of the digitalisation of the economy, the OECD/G20 Inclusive Framework on BEPS invited public comments on the Reports on the Pillar One and Pillar Two Blueprints. The OECD is grateful to the commentators for their input and now publishes the public comments received. This has been announced by the OECD in a press release dated 16 December 2020 ...

OECD publishes information on the state of implementation of the hard-to-value intangibles approach by members of the Inclusive Framework on BEPS

The OECD has published jurisdiction-specific information on the implementation of the hard-to-value intangibles ("HTVI") approach. To date, 40 jurisdictions have provided information on whether their domestic legal system provides for transfer pricing rules aimed at transactions involving HTVI. This has been announced by the OECD in a press release dated 16 December 2020. Furthermore from the press release: The publication of this information is part of the monitoring process of the implementation ...

Transparency on tax rulings now the global norm, according to new peer review assessments for over 120 jurisdictions

As part of continuing efforts to improve tax transparency, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) has reviewed the progress made by 124 jurisdictions in spontaneously exchanging information on tax rulings, in accordance with the BEPS Action 5 minimum standard. The conclusions show that transparency on tax rulings is now a fully-entrenched part of the international tax framework, with 20 000 tax rulings having been identified and 36 000 ...

Inclusive Framework Peer Review Report on the Exchange of Information on Tax Rulings: the Netherlands

As part of continuing efforts to improve tax transparency, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) has reviewed the progress made by 124 jurisdictions in spontaneously exchanging information on tax rulings, in accordance with the BEPS Action 5 minimum standard. The conclusions show that transparency on tax rulings is now a fully-entrenched part of the international tax framework, with 20 000 tax rulings having been identified and 36 000 ...

Inclusive Framework Peer Review Report on the Exchange of Information on Tax Rulings: Sint Maarten

As part of continuing efforts to improve tax transparency, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) has reviewed the progress made by 124 jurisdictions in spontaneously exchanging information on tax rulings, in accordance with the BEPS Action 5 minimum standard. The conclusions show that transparency on tax rulings is now a fully-entrenched part of the international tax framework, with 20 000 tax rulings having been identified and 36 000 ...

Inclusive Framework Peer Review Report on the Exchange of Information on Tax Rulings: Curaçao

As part of continuing efforts to improve tax transparency, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) has reviewed the progress made by 124 jurisdictions in spontaneously exchanging information on tax rulings, in accordance with the BEPS Action 5 minimum standard. The conclusions show that transparency on tax rulings is now a fully-entrenched part of the international tax framework, with 20 000 tax rulings having been identified and 36 000 ...

Inclusive Framework Peer Review Report on the Exchange of Information on Tax Rulings: Aruba

As part of continuing efforts to improve tax transparency, the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) has reviewed the progress made by 124 jurisdictions in spontaneously exchanging information on tax rulings, in accordance with the BEPS Action 5 minimum standard. The conclusions show that transparency on tax rulings is now a fully-entrenched part of the international tax framework, with 20 000 tax rulings having been identified and 36 000 ...

OECD Secretary-General Tax Report to G20 Leaders presented during the November 2020 meeting

On 23 November 2020, the OECD Secretary-General Tax Report to G20 Leaders was presented during the November 2020 meeting in Saudi Arabia. Click here to go to the report (pdf) on the website of the OECD. This report contains two parts. Part I reports on the activities and achievements in the OECD’s international tax agenda. Part II reports on the activities and achievements of the Global Forum on Transparency and ...

OECD secretariat invites public input on the 2020 Review of BEPS Action 14

As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework), the OECD secretariat is seeking public comments on the 2020 review of BEPS Action 14. This was announced by the OECD in a press release dated 18 November 2020. Furthermore from the press release: Background In October 2015 the final report on Action 14 Making Dispute Resolution Mechanisms More Effective was published, containing a minimum standard (the ...

OECD releases 2019 MAP statistics and calls for stakeholder input on the BEPS Action 14 review on Tax Certainty Day

As part of the BEPS Action 14 minimum standard and the wider G20/OECD tax certainty agenda to improve the effectiveness and timeliness of tax-related dispute resolution mechanisms, the OECD released on 18 November 2020 the latest mutual agreement procedure (MAP) statistics covering 105 jurisdictions and almost all MAP cases worldwide. This was announced by the OECD in a press release dated 18 November 2020. Furthermore from the press release: The 2019 ...

Panama deposited its instrument of ratification for the Multilateral BEPS Convention (MLI)

Panama has 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), which now covers almost 1700 bilateral tax treaties, “thus underlining its strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting (BEPS) by multinational enterprises”. This was announced by the OECD in a press release dated 5 ...

Wijziging Ministeriële regeling omzetbelasting: nadere voorwaarden vrijstelling van 7, eerste lid, onderdeel z, Landsverordening omzetbelasting 1999 (Curaçao)

Op 29 oktober 2020 is Ministeriële regeling met algemene werking van de 9de oktober 2020 tot wijziging van de Ministeriële regeling omzetbelasting uitgegeven. Deze ministeriële regeling is geplaatst in het Publicatieblad van Curaçao, jaargang 2020, no. 113 (P.B. 2020, no. 113). Dit publicatieblad is evenwel vooralsnog niet gepubliceerd op de officiële overheidswebsite (www.gobiernu.cw) waar de publicatiebladen worden gepubliceerd [status 10 november 2020]. In deze ministeriële regeling tot wijziging van de ...

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 ...

OECD presents international tax update to G20 Finance Ministers

On 12 October 2020, the OECD has published an update on the continuing negotiations to reach a multilateral, consensus-based solution to the tax challenges arising from the digitalisation of the economy on Monday 12 October 2020: “OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors – October 2020”. Click here to go to the report on the website of the OECD. The publication of the report was ...

International community renews commitment to address tax challenges from digitalisation of the economy

The international community has made substantial progress towards reaching a consensus-based long-term solution to the tax challenges arising from the digitalisation of the economy, and agreed to keep working towards an agreement by mid-2021, according to a Statement (link to the document on the website of the OECD) released on Monday October 12, 2020. This was announced by the OECD in a press release dated 12 October 2020 on the release ...

OECD/G20 Inclusive Framework on BEPS invites public input on the Reports on Pillar One and Pillar Two Blueprints

As part of the ongoing work to develop a solution to the tax challenges of the digitalisation of the economy, the OECD/G20 Inclusive Framework on BEPS is seeking public comments on the Reports on the Pillar One and Pillar Two Blueprints. This was announced by the OECD in a press release dated 12 October 2020. Furthermore from the press release: Background The top priority of the OECD/G20 Inclusive Framework on ...

Curaçao: peer review report (phase 3) of the BEPS Action 13 Country-by-Country reporting initiative

The OECD has released the outcomes of the third phase of peer reviews of the BEPS Action 13 Country-by-Country (CbC) reporting initiative, demonstrating strong progress in continuing efforts to improve the taxation of multinational enterprises (MNEs) worldwide, according to a press release dated 24 September 2020 published on the website of the OECD on the occasion of the report “Country-by-Country Reporting – Compilation of Peer Review Reports (Phase 3): Inclusive Framework ...

Aruba: peer review report (phase 3) of the BEPS Action 13 Country-by-Country reporting initiative

The OECD has released the outcomes of the third phase of peer reviews of the BEPS Action 13 Country-by-Country (CbC) reporting initiative, demonstrating strong progress in continuing efforts to improve the taxation of multinational enterprises (MNEs) worldwide, according to a press release dated 24 September 2020 published on the website of the OECD on the occasion of the report “Country-by-Country Reporting – Compilation of Peer Review Reports (Phase 3): Inclusive Framework on ...

Inclusive Framework on BEPS shows progress in implementing tax transparency through Country-by-Country reporting (Action 13). Compilation of peer review reports phase 3

The OECD has released the outcomes of the third phase of peer reviews of the BEPS Action 13 Country-by-Country (CbC) reporting initiative, demonstrating strong progress in continuing efforts to improve the taxation of multinational enterprises (MNEs) worldwide, according to a press release dated 24 September 2020 published on the website of the OECD. CbC reporting, one of the four minimum standards of the BEPS Project, requires tax administrations to collect and ...

Antwoorden staatssecretaris op kamervragen over de Notitie Fiscaal Verdragsbeleid 2020: vestigingsklimaat, invloed COVID-19 en positie ontwikkelingslanden

Bij brief d.d. 21 september 2020 heeft de staatssecretaris van Financiën–Fiscaliteit en Belastingdienst zijn antwoorden toegestuurd aan de Tweede Kamer op de vragen die de Kamer heeft gesteld in het schriftelijk overleg van 25 juni 2020 over de Notitie Fiscaal Verdragsbeleid 2020 (NFV). Voor de integrale antwoorden van de staatssecretaris verwijzen wij naar het document zelf. Hierna nemen wij wel enkele passages op met betrekking tot een aantal hoofdonderwerpen: Vestigingsklimaat ...