OECD issues discussion draft on transfer pricing for hard-to-value intangibles
On 4 June 2015 the OECD issued a further discussion draft in connection with Action 8 of the action plan on base erosion and profit shifting (BEPS). Action 8 is concerned with assuring that transfer pricing outcomes for intangibles are in line with
See MoreInternational Commission calls for more developing country participation in BEPS
An international panel including Nobel Prize winning economist Joseph Stiglitz and other development experts has called for greater developing country participation in the OECD project on base erosion and profit shifting (BEPS). The Independent
See MoreIMF working paper looks at base erosion, profit shifting and developing countries
The International Monetary Fund (IMF) has published on its website a working paper (No. 15/118) entitled “Base Erosion, Profit Shifting and Developing Countries”. Although the working paper does not necessarily represent the views of the IMF it
See MoreOECD Convenes Group to Develop Multilateral Instrument
The OECD announced on 28 May 2015 that it has begun work on developing a Multilateral Instrument that will implement the tax treaty-related output of the OECD/ G20 action plan on base erosion and profit shifting (BEPS). An ad hoc group has been
See MoreOECD issues new discussion draft on prevention of treaty abuse
On 22 May 2015 the OECD issued a new discussion draft on Action 6 of the action plan on base erosion and profit shifting (BEPS) dealing with the issue of preventing tax treaty abuse. This follows the release of a previous discussion draft on this
See MoreOECD publishes comments received on BEPS action 11
On 13 May 2015 the OECD published on its website comments received on the discussion draft on base erosion and profit shifting (BEPS) action plan Action 11 (Improving the analysis of BEPS). Comments were received from 20 organizations and
See MoreOECD releases new discussion draft under BEPS action 7 on permanent establishments
On 15 May 2015 the OECD published a new discussion draft on action 7 of the action plan on base erosion and profit shifting (BEPS). Action 7 is concerned with changing the definition of a permanent establishment (PE) in the model treaty to prevent
See MoreAustralia: Budget for 2015-2016 Includes BEPS Measures and Exposure Drafts for a New Targeted Anti-Avoidance Rule
The Government of Australia announced the 2015-2016 fiscal budget on May 12, 2015. Australia has included in the budget a country-by-country reporting requirement following the recommendation in the OECD/G20 action plan on base erosion and profit
See MoreOECD releases discussion draft on cost contribution arrangements
On 29 April 2015 the OECD released a discussion draft on cost contribution arrangements. The draft is part of action 8 of the OECD/G20 action plan on base erosion and profit shifting (BEPS) aiming to ensure that transfer pricing outcomes are in line
See MoreOECD: Further BEPS discussion drafts planned for May 2015
Further discussion drafts are to be issued in May 2015 as part of the OECD/G20 action plan on base erosion and profit shifting (BEPS). A discussion draft on cost contribution arrangements is planned for around the end of April 2015. This is part of
See MoreUK: Joint initiative with Australia to combat profit shifting
The Australian Treasurer issued a press release following the G20 meeting on 16 and 17 April indicating potential collaboration with the UK to combat profit shifting. The UK government introduced a Diverted Profits Tax with effect from 1 April
See MoreOECD releases discussion draft on improving the analysis of BEPS
On 16 April 2015 the OECD released a discussion draft on improving the analysis of base erosion and profit shifting (BEPS) actions. This relates to action 11 of the BEPS action plan that concerns improving the availability and analysis of data on
See MoreCanada: Highlights of Pre-election Federal Budget 2015
The Finance Minister delivered the Government’s 2015 pre-election federal budget on 21st April 2015. The tax highlights in the 2015 budget are given below: From the beginning of 2015, the limit for annual contributions to a tax-free savings
See MoreOECD releases discussion draft on CFC rules
Action 3 of the OECD/G20 action plan on base erosion and profit shifting (BEPS) is concerned with taking action on controlled foreign company (CFC) rules. These rules benefit the country of the ultimate parent of a group by subjecting more profits
See MoreOECD releases discussion draft on mandatory disclosure rules
On 31 March 2015 the OECD released a discussion draft in respect of Action 12 of the action plan on base erosion and profit shifting (BEPS). Action 12 calls for disclosure initiatives to deal with the lack of relevant information for tax
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: Meeting of Task Force on Tax and Development
On 18 March 2015 the OECD’s Task Force on Tax and Development met to consider the input resulting from regional network meetings on base erosion and profit shifting (BEPS). The meeting also considered capacity building support provided to
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
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