Latest News2018-01-20T13:54:06+00:00

BEPS Action 13 – Transfer Pricing Documentation

BEPS Action 13 - Transfer Pricing Documentation BEPS Action 13 “Transfer pricing documentation and Country-by-Country Report includes revised guidelines on transfer pricing documentation and Country-by-Country Reporting (CBCR). In particular, the Final Report on Action 13 proposes a three tiered documentation structure: A master file containing high-level information regarding global business operations; A local file specific to each country disclosing details of material related party transactions [...]

BEPS Action 12 – Disclosure of Aggressive Tax Planning

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, taking into consideration the administrative costs for tax administrations and businesses and drawing on the [...]

BEPS Action 11 – Measuring and Monitoring BEPS

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 of BEPS and ensure that tools are available to monitor and evaluate the effectiveness and [...]

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

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 on BEPS Actions 8-10 sets out the aims of the Actions as follows: Action 8 [...]

BEPS Action 7 – Artificially Avoiding PE Status

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 address techniques used to inappropriately avoid the existence of a permanent establishment. The Final Report [...]

BEPS Action 6 – Prevent Treaty Abuse

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 Action 6 includes proposed changes to the OECD Model Tax Convention to set a minimum [...]

BEPS Action 6 – Challenges for Existing Holding Structures?

BEPS Action 6 – Challenges for Existing Holding Structures? The OECD’s final report on “BEPS Action 6: Preventing the Granting of Treaty Benefits in Appropriate Circumstances” identifies tax treaty abuse, in particular, tax treaty shopping as one of the most important sources of BEPS concerns.  This is where a taxpayer inappropriately uses a tax treaty (also known as a double tax agreement) to reduce [...]

BEPS Action 5 – Harmful Tax Practices

BEPS Action 5 - Harmful Tax Practices BEPS Action 5 “Countering harmful tax practices more effectively, taking into account transparency and substance” aims to identify and counter harmful tax practices, taking into account transparency and substance.  This Action aims to revamp the existing framework on harmful tax practices with a priority on improving transparency, including compulsory spontaneous exchange on rulings related to preferential regimes, and [...]

BEPS Action 4 – Interest Deductions and Other Financial Payments

BEPS Action 4 - Interest Deductions and Other Financial Payments BEPS Action 4 “Limiting base erosion involving interest deductions and other financial payments” aims to limit base erosion via interest deductions and other financial payments. Recommendations are expected to be published for domestic law limitations on tax deductions for both related and unrelated party interest expense and economically equivalent payments. The workstream will also develop [...]

BEPS Action 3 – Strengthen CFC Rules

BEPS Action 3 - Strengthen CFC Rules BEPS Action 3 “Designing effective controlled foreign company rules” aims to develop recommendations regarding the design and strengthening of controlled foreign company (CFC) rules, to address concerns over the possibility of creating affiliated non-resident taxpayers and routing income of a resident enterprise through the non-resident affiliate to reduce or avoid taxation. The Final Report on BEPS Action 3 [...]

BEPS Action 2 – Hybrid Mismatch Arrangements

BEPS Action 2 - Hybrid Mismatch Arrangements BEPS Action 2 “Neutralizing the effect of hybrid mismatch arrangements” aims to neutralise the effects of hybrid mismatch arrangements. The OECD intends to do this by making changes to the model tax convention and providing recommendations on the design of domestic rules to prevent hybrids from being a source of “double non-taxation” (through exploiting differences in the [...]

BEPS Action 1 – Tax Challenges of the Digital Economy

BEPS Action 1 - Tax Challenges of the Digital Economy BEPS Action 1 “Addressing the tax challenges of the digital economy” addresses the tax challenges of the digital economy and aims to identify and address the main challenges that the digital economy poses for the existing international tax rules. The issues examined include: The ability of a company to have a significant digital presence [...]

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