international taxation

The Global Forum on Transparency and Exchange of Information for Tax Purposes recently established an Automatic Exchange of Information Peer Review Group (APRG) to take forward its work on ensuring the effective implementation of the Standard for Automatic Exchange of Financial Account Information in Tax Matters (the AEOI Standard). Comprised of 34 Global Forum members, the APRG held its first meeting on 16-18 March 2020 to discuss key issues in ensuring ...

Progress continues with the implementation of the BEPS package, as the OECD releases the second peer review assessing countries’ efforts to implement the Action 6 minimum standard as agreed under the OECD/G20 BEPS Project: Prevention of Treaty Abuse – Second Peer Review Report on Treaty Shopping. The release of the report was announced in a press release on the website of the OECD. From the press release. The second peer review ...

The OECD is grateful to the commentators for their input on the 2020 Review of Country-by-Country Reporting (BEPS Action 13 Minimum Standard) and has published the public comments received. This was announced with a press release published on 9 March 2020 the website of the OECD. From the press release. On 6 February 2020, interested parties were invited to provide comments. For more information, click here to go to the press ...

On 25 February 2020, the OECD released IT-formats and guidance to support the technical implementation of the OECD Treaty Relief and Compliance Enhancement (TRACE) initiative, as well as to facilitate the wider use of the OECD Common Transmission System (CTS) for the exchange of information between tax administrations. This was announced with a press release published on the website of the OECD. From the press release: TRACE is a standardised ...

De vaste commissie voor Financiën heeft een aantal vragen en opmerkingen voorgelegd aan de Staatssecretaris van Financiën over de brief van 10 oktober 2019 over hoofdlijnen van de eerste pijler van een nieuw internationaal stelsel voor belastingheffing in een digitaliserende economie (Kamerstuk 32 140, nr. 60). De vragen en opmerkingen zijn op 21 november 2019 aan de Staatssecretaris van Financiën voorgelegd. Bij brief van 10 februari 2020 zijn de vragen ...

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 ...

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 ...

As part of the ongoing work of the Committee on Fiscal Affairs, the OECD is seeking public comments on the draft Model Rules for Reporting for Platform Operators with respect to Sellers in the Sharing and Gig Economy. This was announced with a press release published on the website of the OECD. From the press release: BACKGROUND The market of online platforms facilitating the "sharing" and "gig" economies is growing rapidly ...

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), ...

Het Nederlandse Ministerie van Financiën heeft een brochure uitgegeven over het Multilateraal Instrument (MLI) en Nederlandse belastingverdragen. Het MLI maakt het voor landen mogelijk op een snelle en efficiënte wijze hun belastingverdragen aan te passen om belastingontwijking tegen te gaan, zonder dat hiervoor nieuwe onderhandelingen nodig zijn. Het MLI bevat namelijk bepalingen tegen belastingontwijking die doorwerken in belastingverdragen van landen die daarvoor kiezen. Het MLI geldt ook voor Nederland. In ...

On 18 February 2020, EU Finance Ministers updated the EU list of non-cooperative tax jurisdictions. This was announced with a press release published on the website of the European Commission. Further from the press release: Four countries or territories- Cayman Islands, Palau, Panama and Seychelles - have been added to the list of non-cooperative tax jurisdictions, as they failed to comply with the required standards within the deadline. These join ...

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 ...

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 ...

Bij Landsbesluit van 13 januari 2020 is de Sector-directeur Fiscale Zaken van het Ministerie van Financiën, gemachtigd om de openbare rechtspersoon Curaçao te vertegenwoordigen bij de ondertekening van de aan het landsbesluit gehechte overeenkomst ter uitvoering van artikel 4 van het Verdrag tussen het Koninkrijk der Nederlanden, ten behoeve van de Nederlandse Antillen en de Regering van de Verenigde Staten van Amerika inzake de uitwisseling van gegevens met betrekking tot ...

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 ...

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 ...

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 Organisation for Economic Co-operation and Development (OECD) and the Intra-European Organisation of Tax Administrations (IOTA) signed the renewal of a Memorandum of Understanding (MOU) for Co-operation between both Parties. This was announced in a press release published on the website of the OECD. The two organisations, which have worked together since 2000, expressed their intention to expand the co-operation in promoting fair and efficient tax systems and enhancing the ...

Voor multinationals wordt het moeilijker om te profiteren van belastingvoordelen van Europese regels door uitspraken van het Europese Hof van Justitie. Wereldwijd kan het profijt van het omsluizen van hun inkomen via brievenbusfirma’s wel met 20 procent dalen. Wanneer ook niet EU-lidstaten meedoen wordt het effect groter. Dat blijkt uit een rapport van het Centraal Planbureau (CPB): ‘Limitation of holding structures for intra-EU dividends: A blow to tax avoidance?’, zo ...

The OECD has published two self-assessment maturity models on tax debt management and the reduction of compliance burdens, both critical areas for successful tax administration. Maturity models set out descriptions of capabilities and performance in a particular function or set of activities across a number of levels of increasing maturity, in the case of these models from an emerging to an aspirational level. These models, the first in a new ...

As part of continuing efforts to address BEPS concerns, the Inclusive Framework on BEPS (Inclusive Framework) has now assessed 112 jurisdictions' progress in spontaneously exchanging information on tax rulings, in accordance with Action 5 of the OECD/G20 BEPS package. This includes the first review for newer members of the Inclusive Framework, as well as certain developing countries that had requested additional time and were deferred from the previous years' peer ...

The Inclusive Framework on BEPS has released additional interpretative guidance to give greater certainty to tax administrations and MNE Groups on the implementation and operation of Country-by-Country (CbC) Reporting (BEPS Action 13). The new guidance makes clear that, under the BEPS Action 13 minimum standard, the automatic exchange of CbC reports filed under local filing rules is not intended. The release of the report was announced in a press release ...

Tax revenues in advanced economies reached a plateau during 2018, with almost no change seen since 2017, according to new OECD research. This ends the trend of annual increases in the tax-to-GDP ratio seen since the financial crisis. The 2019 edition of the OECD’s annual Revenue Statistics publication shows that the OECD average tax-to-GDP ratio was 34.3% in 2018, virtually unchanged since the 34.2% in 2017. The release of the report was ...

With a press release dated 3 December 2019, the OECD informed that it received the public comments on certain aspects of the Global Anti-Base Erosion (GloBE) Proposal under Pillar Two. Interested parties were invited on 8 November 2019 to provide comments on the relevant aspects. The OECD is grateful to the commentators for their input and has published the public comments received. For more information, click here to go to ...

Tuesday 26th of November marked an important milestone for the Organisation for Economic Co-operation and Development and the United Nations Development Programme Tax Inspectors Without Borders initiative (TIWB) with the launch of a project on automatic exchange of information (AEOI). The project, which will be co-ordinated with the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum), was unveiled during its 10th Anniversary Meeting in Paris, France. This ...

On 26-27 November, the 10th Anniversary Meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum) in Paris brought together more than 500 delegates from 131 member jurisdictions for renewed discussions on efforts to advance the tax transparency agenda. This was announced in a press release on the website of the OECD. From the press release: Ten years since the G20 declared the end of banking ...

The OECD is now gathering input for the tenth batch of Stage 1 dispute resolution peer reviews, according to a press release on the website of the OECD. This tenth batch includes the peer review of Aruba. 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 ...

On 12 November 2019, the Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum) published eight peer review reports assessing compliance with the international standard on transparency and exchange of information on request (EOIR). This was announced in a press release published on the website of the OECD. From the press release: These reports are part of the second round of Global Forum reviews, which ...

As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS, the OECD secretariat is seeking public comments on certain aspects of the Global Anti-Base Erosion (GloBE) Proposal under Pillar Two. This was announced in a press release published on the website of the OECD. From the press release: The consultation document (available soon in French) focuses on specific technical issues in respect of the GloBE proposal where input ...

On 12 November 2019, the Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum) published eight peer review reports assessing compliance with the international standard on transparency and exchange of information on request (EOIR). The release of the reports was announced in a press release published on the website of the OECD. These reports are part of the second round of Global Forum reviews, which ...