OECD/G20 BEPS Project

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 continuous efforts to enhance tax certainty. One of the elements of the Action 14 minimum standard requires jurisdictions to seek to resolve mutual agreement procedure ("MAP") cases within an average timeframe of ...

On 21 November 2017, the OECD Council approved the contents of the 2017 Update to the OECD Model Tax Convention (the OECD Model). The 2017 Update, which was previously approved by the Committee on Fiscal Affairs on 28 September 2017, will be incorporated in a revised version of the OECD Model that will be published in the next few months. The 2017 Update primarily comprises changes to the OECD Model that were developed through ...

As we reported today in a separate article, the Netherlands is among the first six peer review reports on implementation of BEPS minimum standards on improving tax dispute resolution mechanisms which were released by the OECD on 26 September 2017. Interesting to learn for the Dutch Caribbean tax practice is that the treaty analysis in the peer review relating to the Netherlands also includes, as we understand, the “Tax Arrangement ...

On 26 September 2017, as part of continuing efforts to improve the international tax framework, the OECD has released the first analysis of individual country efforts to improve dispute resolution mechanisms. The six peer review reports represent the first evaluation of how countries are implementing new minimum standards agreed in the OECD/G20 BEPS Project. The first six peer review reports relate to implementation by Belgium, Canada, the Netherlands, Switzerland, the United ...