Tax dispute resolution: OECD releases revised methodology for the BEPS Action 14 peer reviews, additional data points in the MAP Statistics and a new framework for APA Statistics. Curaçao scheduled for peer review in November 2023, Aruba in November 2024

Following the successful completion of peer reviews under the existing BEPS Action 14 Assessment Methodology, the OECD/G20 Inclusive Framework on BEPS has agreed a new Assessment Methodology for continuing the robust peer review process that seeks to increase efficiencies and improve the timeliness of the resolution of double taxation disputes. In addition, the Inclusive Framework has also agreed new data points to be reported in the annual Mutual Agreement Procedure ...

OECD releases new mutual agreement procedure statistics and country awards on the resolution of international tax disputes

The OECD has released the latest mutual agreement procedure (MAP) statistics covering 127 jurisdictions and practically all MAP cases worldwide. This has been announced with a news release on the website of the OECD. These statistics form 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. Further from the news release: The 2021 MAP Statistics* show ...

New peer review assessments on tax dispute resolution released (MAP – BEPS Action 14)

Despite the significant disruption caused by the ongoing COVID-19 pandemic and the necessity to hold all meetings virtually, work has continued with the release on Tuesday 13 September 2022 of the Stage 2 peer review monitoring reports regarding the minimum standard to improve the resolution of tax-related disputes between jurisdictions (BEPS Action 14) for Aruba, Bahrain, Barbados, Gibraltar, Greenland, Kazakhstan, Oman, Qatar, Saint Kitts and Nevis, Thailand, Trinidad and Tobago, ...

Stage 2 peer review assessment on tax dispute resolution (MAP): Overall Aruba meets most of the elements of the BEPS Action 14 Minimum Standard (Aruba)

Tuesday, September 13, 2022, the OECD released the stage 2 peer review monitoring report for Aruba regarding the minimum standard to improve the resolution of tax-related disputes between jurisdictions under BEPS Action 14. This has been announced with a news release [external link] on the website of the OECD. Under BEPS Action 14, members of the OECD/G20 Inclusive Framework on BEPS have committed to implement a minimum standard to strengthen the ...

Making tax dispute resolution more effective: New peer review assessments for inter alia Bahamas, Bermuda, British Virgin Islands and Cayman Islands

Under BEPS Action 14, jurisdictions have committed to implement a minimum standard to improve the resolution of tax-related disputes between jurisdictions. Despite the significant disruption caused by the ongoing COVID-19 pandemic and the necessity to hold all meetings virtually, work has continued with the release on Thursday 14 April 2022, of the Stage 2 peer review monitoring reports for Andorra, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau (China), Morocco and Tunisia. This has been announced by the ...

Countries continue the successful implementation of international standards on harmful tax practices and tax dispute resolution

Progress continues in combatting harmful tax practices and providing greater tax certainty. New outcomes on the review of preferential tax regimes and new peer review reports on Mutual Agreement Procedures have been approved by the OECD/G20 Inclusive Framework on BEPS, which groups over 140 countries and jurisdictions on an equal footing for multilateral negotiation of international tax rules. This has been announced by the OECD with a press release dated 24 ...

Tax dispute resolution – MAP peer review report (Stage 2): Curaçao meets all of the elements of the Action 14 Minimum Standard and solved all of the identified deficiencies

New peer review reports on Mutual Agreement Procedures (MAP) have been approved by the OECD/G20 Inclusive Framework on BEPS, which groups over 140 countries and jurisdictions on an equal footing for multilateral negotiation of international tax rules. This has been announced by the OECD with a press release dated 24 January 2022 on the occasion of the release of the peer review reports. Curaçao The Stage 2 peer review monitoring ...

New mutual agreement procedure statistics on the resolution of international tax disputes released on OECD 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 the latest mutual agreement procedure (MAP) statistics covering 118 jurisdictions and practically all MAP cases worldwide. This has been announced on Tuesday 22 November 2021 with a news release on the website of the OECD. Furthermore from the news release: ...

Progress continues in making tax dispute resolution more effective and in improving tax transparency through Country-by-Country reporting

Under OECD/G20 Inclusive Framework on BEPS, 140 jurisdictions have committed to implement minimum standards to improve the taxation of multinational enterprises (MNEs) worldwide. On Monday, 18 October 2021, the OECD has released the latest outcomes of the implementation of BEPS Action 13 on the transparency of global operations of large MNEs and BEPS Action 14 on the resolution of tax related disputes between jurisdictions. This has been announced with a ...

Fourth annual peer review of BEPS Action 13 considering implementation of the CbC reporting minimum standard: Curaçao has fully implemented the BEPS Action 13 minimum standard and meets all of the terms of reference

On Monday 18 October 2021, the OECD has released the latest outcomes of the implementation of BEPS Action 13 on the transparency of global operations of large MNEs and BEPS Action 14 on the resolution of tax related disputes between jurisdictions. This has been announced with a news release on the website of the OECD. The BEPS Action 13 minimum standard on Country-by-Country reporting (CbC), requires tax administrations to collect ...

Fourth annual peer review of BEPS Action 13 considering implementation of the CbC reporting minimum standard: recommendations for Aruba

On Monday 18 October 2021, the OECD has released the latest outcomes of the implementation of BEPS Action 13 on the transparency of global operations of large MNEs and BEPS Action 14 on the resolution of tax related disputes between jurisdictions. This has been announced with a news release on the website of the OECD. The BEPS Action 13 minimum standard on Country-by-Country reporting (CbC), requires tax administrations to collect ...

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 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 ...

Besluit Onderlinge overlegprocedures van 11 juni 2020 gepubliceerd in de Staatscourant, vervangt het besluit van 29 september 2008 (Caribisch Nederland)

Op 22 juni 2020 is het Besluit Onderlinge overlegprocedures van 11 juni 2020 van de Staatssecretaris van Financiën, nr. 2020-0000101607, gepubliceerd in de Staatscourant, jaargang 2020, no. 32689 (Stcrt. 2020, 32689). Dit besluit bevat een nadere beschrijving en invulling van de onderlinge overlegprocedure op grond van de Wet fiscale arbitrage, een bilateraal belastingverdrag of het EU-arbitrageverdrag. Meerdere regelingen geven een belanghebbende de mogelijkheid om een (dreigend) geschil over de toepassing ...

Onderlinge overlegprocedure vastgesteld en gepubliceerd in de Landscourant (Aruba)

In de Landscourant van Aruba van 25 mei 2020, jaargang 2020, no. 11 (Lcrt. 2020 no. 11, blz. 4-9) is het besluit van de minister van Financiën, Economische Zaken en Cultuur van 18 mei 2020 met het beleid inzake de onderlinge overlegprocedure gepubliceerd. Dit beleid bevat een beschrijving en invulling van de onderlinge overlegprocedure op grond van een verdrag op fiscaal gebied. Het beleid is in werking getreden met ingang ...

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 releases sixth round of BEPS Action 14 peer review reports on improving tax dispute resolution mechanisms. The reports include Argentina, Chile and Colombia

The work on BEPS Action 14 continues with the publication of the sixth round of stage 1 peer review reports, as announced on 24 October 2019 in a press releases on the website of the OECD. Each report assesses a country’s efforts to implement the Action 14 minimum standard as agreed to under the OECD/G20 BEPS Project. From the press release: The reports of Argentina, Chile, Colombia, Croatia, India, Latvia, ...

OECD releases first stage 2 monitoring reports for BEPS Action 14 on improving tax dispute resolution mechanisms, including a report on the Netherlands

The work on BEPS Action 14 continues with the publication on 13 Augustus 2019 of the first round of stage 2 peer review monitoring reports, which consists of monitoring the follow-up of any recommendations resulting from jurisdictions' stage 1 peer review reports. This was announced in a press release published on the website of the OECD. The stage 2 monitoring reports for Belgium, Canada, the Netherlands, Switzerland, United Kingdom and the United States evaluate the progress made by ...

OECD invites taxpayer input on ninth batch of dispute resolution peer reviews

Improving the tax treaty dispute resolution process is a top priority of the BEPS Project. The Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan was launched in December 2016 with the peer review process of the first eight batches now well underway. This was announced in a press release published on the website of the OECD. The peer review process is ...

OECD invites taxpayer input on eighth batch of dispute resolution peer reviews – includes Curaçao

Improving the tax treaty dispute resolution process is a top priority of the BEPS Project. The Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan was launched in December 2016 with the peer review process now well underway. The peer review process is conducted in two stages. Under Stage 1, implementation of the Action 14 minimum standard is evaluated for Inclusive Framework ...

BEPS peer review reports on treaty shopping: no jurisdiction has raised any concerns about their agreements with Curaçao

On 14 February 2019, the OECD released additional peer review reports assessing countries’ efforts to implement the Action 6 minimum standards as agreed under the OECD/G20 BEPS Project. The release of this report has been announced with a press release dated 14 February 2019 as published on the website of the OECD. The first peer review report on the implementation of the Action 6 minimum standard on treaty shopping reveals ...

OECD releases BEPS peer review reports on improving tax dispute resolution mechanisms and preventing treaty shopping

Progress continues with the implementation of the BEPS package, as the OECD releases additional peer review reports assessing countries’ efforts to implement the Action 6 and Action 14 minimum standards as agreed under the OECD/G20 BEPS Project. The release of these reports has been announced with a press release dated 14 February 2019 as published on the website of the OECD. ACTION 6: PREVENTING THE GRANTING OF TREATY BENEFITS IN ...

OECD invites taxpayer input on seventh batch of Dispute Resolution peer reviews

Improving the tax treaty dispute resolution process is a top priority of the BEPS Project. The Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan was launched in December 2016 with the peer review process now well underway. The peer review process is conducted in two stages. Under Stage 1, implementation of the Action 14 minimum standard is evaluated for Inclusive Framework ...

OECD releases 2017 global mutual agreement procedure statistics

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 wider G20/OECD tax certainty agenda. The Action 14 minimum standard requires jurisdictions to seek to resolve mutual agreement procedure ("MAP") cases within an average timeframe of 24 months. To monitor compliance with this, ...

OECD releases fourth round of BEPS Action 14 peer review reports on improving tax dispute resolution mechanisms

The work on BEPS Action 14 continues with yesterday’s publication of the fourth round of stage 1 peer review reports, as announced in a press release published on the website of the OECD on 30 August 2018. Each report assesses a country’s efforts to implement the Action 14 minimum standard as agreed to under the OECD/G20 BEPS Project. The reports of Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand and Portugal published today contain over 130 targeted recommendations that will ...

OECD invites taxpayer input on sixth batch of Dispute Resolution peer reviews (BEPS Action 14)

The OECD invites taxpayer input on sixth batch of Dispute Resolution peer reviews (BEPS Action 14), according to a press release dated 26 July 2018 published on the website of the OECD. From the press release: Improving the tax treaty dispute resolution process is a top priority of the BEPS Project. The Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan was ...

Update to OECD Model Tax Convention released

The latest edition of the OECD Model Tax Convention has been released on 18 December 2017, incorporating significant changes developed under the OECD/G20 project to address base erosion and profit (BEPS), according to an announcement dated 18 December 2017 on the website of the OECD. The OECD Model Tax Convention, a model for countries concluding bilateral tax conventions,  plays a crucial role in removing tax related barriers to cross border trade and ...