OECD: Comments on proposed changes to the commentary on Article 9 of the OECD Model
On 3 June 2021 the OECD published comments received from interested parties in response to a public discussion draft on proposed changes to the commentary to Article 9 (associated enterprises) of the OECD Model Tax Convention. The comments will be
See MoreOECD: Request for input on proposed changes to commentary on Article 9 of OECD Model
On 29 March 2021 the OECD issued a public discussion draft on proposed changes to the commentary to Article 9 (associated enterprises) of the OECD Model Tax Convention. The amendments are to be included in the next update of the OECD
See MorePlatform for Collaboration on Tax: Toolkit on Tax Treaty Negotiations
The Platform for Collaboration on Tax (PCT) was set up by the IMF, OECD, UN and World Bank Group. The PCT has been developing a series of toolkits to guide developing countries in the implementing policy options. The PCT's Toolkit on Tax Treaty
See MoreGerman Upper House Approves MLI to Implement Tax Treaty Related BEPS Measures
On 6 November 2020 the Bundesrat (the upper house in the German parliament) gave its approval to ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, also known as the
See MoreAustralia: Federal Court rules on tax position of UK citizen in Australia with a Working Holiday Visa
In a judgment of 6 August 2020 the Australian Federal Court ruled in favour of the Commissioner of Taxation in a case involving the residency test for a UK citizen staying in Australia on a Working Holiday Visa (WHV). The Court found that the UK
See MoreOECD: Platform for Collaboration on Tax Finalises Toolkit on Offshore Indirect Transfers
On 4 June 2020 the Platform for Collaboration on Tax issued a final version of the Toolkit on the Taxation of Offshore Indirect Transfers. The Toolkit provides guidance in relation to designing measures to enable a country to tax gains arising
See MoreOECD: Comments received on draft updates to Model Tax Convention
On 11 August 2017 the OECD published comments received on the draft 2017 updates to the OECD Model Tax Convention and commentary. The draft updates had been published for comment on 11 July 2017. Comments were received from the BEPS Monitoring
See MoreDTA between Japan and Slovenia will enter into Force
The Japanese Ministry of Finance on 26 July 2017 issued a press release announcing that the double taxation agreement (DTA) between Japan and Slovenia, signed on 10 September 2016, will enter into force on 23 August 2017. The Treaty contains
See MoreOECD: Draft 2017 updates to the Model Tax Convention
On 11 July 2017 the OECD issued the draft 2017 update of the OECD Model Tax Convention. The changes are to be submitted later in 2017 for approval by the Committee on Fiscal Affairs and the OECD Council. Some parts of the update relate to the
See MoreOECD: Discussion draft on treaty residence of pension funds
On 29 February 2016 the OECD issued a discussion draft on the tax treaty residence of pension funds. Changes are to be made to the OECD Model to ensure that a recognized pension fund is treated for the purpose of the tax treaty as resident in the
See MoreOECD: Mutual Agreement Procedure Statistics for 2014
On 24 November 2015 the OECD released the statistics on the Mutual Agreement Procedure (MAP) for the 2014 reporting period. For OECD countries there were 2,266 new MAP cases in 2014. The inventory of MAP cases at the end of the reporting period was
See MoreCyprus-OECD Convention and protocol on Mutual Administrative Assistance in Tax Matters enters into force
The multilateral convention and protocol between Cyprus and OECD regarding mutual administrative assistance in tax matters entered into force on 1 April 2015. The convention and the protocol were signed on 10 July, 2014. The convention and the
See MoreOECD holds public consultation on transfer pricing issues
On 19 and 20 March 2015 the OECD held a public consultation on transfer pricing matters arising from the action plan on base erosion and profit shifting. The first day of the conference dealt with the draft amendments and additions to Chapter 1 of
See MoreOECD publishes comments on prevention of artificial avoidance of PE status
On 13 January 2015 the OECD published on its website the comments received from interested parties on the discussion draft in respect of Action 7 of the action plan on base erosion and profit shifting (BEPS). This concerns prevention of artificial
See MoreOECD publishes comments received on restriction of treaty benefits
On 13 January 2015 the OECD published on its website the comments received from interested parties on Action 6 of the action plan on base erosion and profit shifting (BEPS). This concerns the prevention of tax treaty abuse and involves developing
See MoreCanada: Comments for OECD discussion draft on international VAT-GST guidelines
The Organization for Economic Co-operation and Development (OECD) has published a discussion draft on 18th December 2014 entitled “Guidelines on Place of Taxation for Business-to-Consumer Supplies of Services and Intangibles and Provisions on
See MoreOECD Releases Mutual Agreement Procedure Statistics for 2013
The OECD Model Tax Convention includes a provision for a mutual agreement procedure (MAP) in Article 25. Under this procedure the competent authorities of the two contracting states are required to endeavor to reach agreement to resolve issues that
See MoreOECD: Released a Roadmap to support developing countries in implementing the new global standard for the automatic exchange of tax information.
The Organization for Economic Co-operation and Development (OECD) released on September 22, 2014, goals to support developing countries in executing the new global standard for the automatic exchange of tax information. Finance Ministers of the
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