OECD: Report on branch mismatch rules
On 28 July 2017 the OECD’s Committee on Fiscal Affairs (CFA) issued a document entitled Neutralising the Effects of Branch Mismatch Arrangements, Action 2. This document was issued as part of the implementation of the action plan on base erosion
See MoreOECD updates guidance on country by country reporting
On 20 July 2017 the OECD published updates to the guidance on country by country (CbC) reporting requirements under Action 13 of the project on base erosion and profit shifting (BEPS). This guidance for tax administrations and multinational groups
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 MoreSlovak Republic: Government declares new corporate tax measures
The Government announced several changes in the corporate taxation area on 20th June 2017, including the introduction of a new patent box regime in line with the modified nexus approach developed as part of BEPS Action 5. The government also
See MoreAustria: Federal Council approves MLI to implement tax treaty related BEPS measures
On 5 July 2017, the Federal Council of Austria approved the Multilateral Convention to Implement Tax Treaty Related Measures to prevent Base Erosion and Profit Shifting (MLI). Austria must now complete the ratification process and deposit its
See MoreOECD: Inclusive framework meeting for francophone countries
The second regional meeting of the Inclusive Framework for the francophone countries was held from 3 to 5 July 2017 in Benin. The meeting was organized by the OECD in partnership with CREDAF, an organization that brings together the tax
See MoreOECD: 2017 edition of the transfer pricing guidelines issued
On 10 July 2017 the OECD issued the 2017 edition of the OECD transfer pricing guidelines. The amendments made in the latest edition of the guidelines mainly arise from the transfer pricing aspects of the conclusions and recommendations of the
See MoreG20 final communiqué comments on international tax
The final communiqué from the G20 summit held on 7 and 8 July 2017 covers international tax among other matters. The G20 reaffirmed its commitment to the implementation of the project on base erosion and profit shifting (BEPS) and encouraged
See MoreMauritius signs MLI to implement tax treaty related BEPS measures
On 5 July 2017 at the OECD headquarters in Paris, the Ministry of Finance and Economic Development of Mauritius has signed the Multilateral Convention to Implement Tax Treaty Related Measures to prevent Base Erosion and Profit Shifting (MLI). Based
See MoreVietnam publishes guidance on new transfer pricing requirements
The Ministry of Finance on 22 June 2017 published Circular 41/2017 / TT-BTC (28 April 2017), which provides some guidelines for the application of Decree No 20/2017 and this Circular will take effect on 1 May 2017. Circular 41/2017 introduced some
See MoreOECD: Comments received on draft HTVI implementation guidance
On 5 July 2017 the OECD published comments received in relation to the BEPS discussion draft on the implementation guidance on Hard-to-Value Intangibles (HTVIs). The comments received focus on a range of points including the uncertainty arising for
See MoreOECD Director-General reports to G20 leaders
The OECD Secretary-General’s report to the G20 leaders was published on the OECD website on 5 July 2017. The report consists of an international tax update by the Director General and a progress report to the G20 by the Global Forum on
See MoreVietnam Joins the Inclusive Framework on BEPS
On 21 June 2017, the OECD published a new list of countries and jurisdictions participating in the Inclusive Framework on Base Erosion and Profit Shifting (BEPS). Based on this list, Vietnam has become the 100th jurisdiction to join the Inclusive
See MoreOECD: Meeting of Inclusive Framework on BEPS
On 22 June 2017 the third meeting of the inclusive framework on base erosion and profit shifting (BEPS) took place in the Netherlands with representatives of 83 countries and jurisdictions and 12 international and regional organizations. The
See MoreOECD: Revised guidance on profit splits
A discussion draft issued by the OECD on 22 June 2017 contains revised guidance on profit splits. This guidance is issued in relation to the clarification and strengthening of the guidance on the transactional profit split method as outlined in the
See MoreOECD: discussion draft sets out additional guidance on attribution of profits to PEs
On 22 June 2017 the OECD issued a new discussion draft with guidance on attribution of profits to permanent establishments (PEs), to replace the previous draft published in July 2016. The new discussion draft outlines the general principles for the
See MoreThailand Joins the Inclusive Framework on BEPS
Thailand has become the 98th jurisdiction to join the Inclusive Framework (IF) on BEPS and will participate at the next plenary session of the IF with the same rights as the all other IF members, which will take place on 21/22. June 2017 in
See MoreHong Kong signs the Multilateral Convention
On 7 June 2017, the Commissioner of China's State Administration of Taxation (SAT) signed, on behalf of Hong Kong, the OECD Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, which aims to
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