OECD releases Transfer Pricing Guidance on Financial Transactions
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 ...
OECD releases new guidance on the application of the approach to hard-to-value intangibles and the transactional profit split method under BEPS Actions 8-10
On 21 June 2018, the OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles, under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method, under BEPS Action 10. From the press release dated 21 June 2018 as published on the website of the OECD: In October 2015, as part of the final BEPS package, the OECD/G20 published ...
OECD releases additional guidance on the attribution of profits to a permanent establishment under BEPS Action 7
On 22 March 2018, the OECD released the report Additional Guidance on the Attribution of Profits to Permanent Establishments (BEPS Action 7), the OECD announced in a press release published on its website on 22 March 2018. In October 2015, as part of the final BEPS package, the OECD/G20 published the report on Preventing the Artificial Avoidance of Permanent Establishment Status. The Report recommended changes to the definition of permanent ...
Public comments received on the draft contents of the 2017 Update to the OECD Model Tax Convention
On 11 July 2017, the OECD released the draft contents of the 2017 Update to the OECD Model Tax Convention. Interested parties were invited to provide comments with respect to parts of the 2017 Update to the OECD Model Tax Convention that had not previously been released for comments. See also CFN dated 14-07-2017, nr. 2017/25. The OECD has published the public comments received. It is expected that the contents of the ...
OECD releases the draft contents of the 2017 update to the OECD Model Tax Convention
On 11 July 2017 the OECD Committee on Fiscal Affairs released the draft contents of the 2017 update to the OECD Model Tax Convention prepared by the Committee's Working Party 1. The update has not yet been approved by the Committee on Fiscal Affairs or by the OECD Council. Comments are requested at this time only with respect to certain parts of the 2017 update that have not previously been released for comments ...