OECD releases guidance on the spontaneous exchange by no or only nominal tax jurisdictions

As part of BEPS Action 5 to curb harmful tax practices, jurisdictions may only maintain preferential regimes if certain "substantial activities" requirements are met. In order to ensure a level playing field, these requirements must also apply to jurisdictions with zero or only nominal tax rates. As a result, the Inclusive Framework on BEPS decided in November 2018 to resume the application of the substantial activities requirement for no or ...
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