BEPS Action 12 – Disclosure of Aggressive Tax Planning

2018-02-11T18:13:47+00:00

BEPS Action 12 - Disclosure of Aggressive Tax Planning BEPS Action 12 “Mandatory disclosure rules” aims to require taxpayers to disclose their aggressive tax planning arrangements. This will be addressed through the development of recommendations regarding the design of mandatory disclosure rules for aggressive or abusive transactions, arrangements, or structures, [...]

BEPS Action 12 – Disclosure of Aggressive Tax Planning2018-02-11T18:13:47+00:00

BEPS Action 11 – Measuring and Monitoring BEPS

2018-02-11T18:26:32+00:00

BEPS Action 11 - Measuring and Monitoring BEPS BEPS Action 11 “Measuring and monitoring BEPS” aims to establish methodologies to collect and analyse data on BEPS and the actions to address it. The OECD intends to do this by developing recommendations regarding indicators of the scale and economic impact [...]

BEPS Action 11 – Measuring and Monitoring BEPS2018-02-11T18:26:32+00:00

BEPS Actions 8-10 – Align Transfer Pricing Outcomes with Value Creation

2018-02-12T02:51:31+00:00

BEPS Actions 8-10 - Align Transfer Pricing Outcomes with Value Creation BEPS Actions 8-10, “Aligning Transfer Pricing Outcomes with Value Creation” includes new guidance on how to allocate transfer price risk, transfer price intangibles, hard-to-value intangibles (HTVI), commodities, low value-adding intra-group services and cost contribution arrangements. Specifically, the Final Report [...]

BEPS Actions 8-10 – Align Transfer Pricing Outcomes with Value Creation2018-02-12T02:51:31+00:00

BEPS Action 7 – Artificially Avoiding PE Status

2018-02-12T03:03:46+00:00

BEPS Action 7 - Artificially Avoiding PE Status BEPS Action 7  “Preventing the artificial avoidance of permanent establishment status” contains agreed amendments to the definition of “permanent establishment” in Article 5 of the OECD Model Tax Convention, which is widely used as the basis for negotiating tax treaties. These changes [...]

BEPS Action 7 – Artificially Avoiding PE Status2018-02-12T03:03:46+00:00

BEPS Action 6 – Prevent Treaty Abuse

2018-02-12T03:15:19+00:00

BEPS Action 6 - Prevent Treaty Abuse BEPS Action 6 “Preventing the granting of treaty benefits in inappropriate circumstances” recommends that countries include in their tax treaties an express statement that their common intention is to eliminate double taxation without creating opportunities for treaty shopping. The Final Report on BEPS [...]

BEPS Action 6 – Prevent Treaty Abuse2018-02-12T03:15:19+00:00