UK: Consultation on Hybrid Mismatch Arrangements
An issue that is ongoing but will not be included in the UK Finance Bill 2015 is the introduction of measures to combat hybrid mismatch arrangements. A consultation on the subject was announced in October 2014 and in December 2014 a consultation
See MoreOECD study on the distributional effects of consumption taxes
A study recently released by the OECD on the distributional effects of consumption taxes in OECD countries is a result of a joint venture between the OECD and the Korean Institute of Public Finance. Recent OECD research has shown that there are
See MoreOECD publishes latest study on consumption tax trends
The latest edition of the OECD study on consumption tax trends has been published. The OECD study covers the general taxes on goods and services such as VAT and sales tax plus the taxes on specific goods and services such as insurance premium tax,
See MoreSouth Africa: Proposal to ChangeTransfer Pricing Documentation and CFC Rules
The South African Finance Minister Nhlanhla Nene proposed new transfer pricing documentation and reporting rules and proposed to revise controlled foreign company (CFC) rules relating to the digital economy, in his budget speech for 2015. The
See MoreOECD holds webcast to provide updates on the BEPS project
On 12 February 2015 the OECD held a webcast to update interested parties on the progress made in the action plan on base erosion and profit shifting (BEPS). The OECD and G20 countries have agreed on three elements that will enable implementation of
See MoreOECD publishes comments received on limiting base erosion through financial payments
On 11 February 2015 the OECD published on its website comments received from interested parties in respect of the discussion draft on interest deductions and other financial payments, corresponding to action 4 of the OECD/G20 action plan on base
See MoreOECD publishes comments received on transfer pricing aspects of commodity transactions
The OECD has published on its website comments received on the discussion draft on the transfer pricing aspects of cross border commodity transactions. This was issued as part of the response to action 10 of the base erosion and profit shifting
See MoreOECD publishes comments received on draft changes to the transfer pricing guidelines
On 10 February 2015 the OECD published comments received in respect of the discussion draft on changes to the OECD guidelines and other special measures that could be taken in respect of transfer pricing issues raised by actions 8, 9 and 10 of the
See MoreIndia: Amendments to Transfer Pricing Guidelines Issued
The Central Board of Direct Taxes released amendments to the transfer pricing guidelines on 4 February 2015. The “simplified” transfer pricing documentation rules were released by a notification dated 4 February 2015 for domestic transactions of
See MoreOECD to present BEPS action plan developments to the G20 Finance Ministers
The OECD is to give a presentation on the project on base erosion and profit shifting (BEPS) to the G20 Finance Ministers when they meet on 9 and 10 February 2015. The OECD has agreed with the G20 countries on three important elements that will move
See MoreEuropean Union: Anti abuse clause added to parent subsidiary directive
On 27 January 2015 the Council of the European Union (EU) amended the parent subsidiary directive to add a binding anti-abuse clause. This is designed to prevent tax avoidance and aggressive tax planning, and to ensure more consistency in the
See MoreEU: sets up new mandate for the Joint Transfer Pricing Forum
As the previous mandate for the EU Joint Transfer pricing Forum had expired, on 26 January 2015 the European Commission issued Commission Decision C (2015) 247 in respect of setting up a new EU Joint Transfer Pricing Forum expert group. The previous
See MoreOECD Holds Public Discussion on Dispute Resolution Mechanisms
On 23 January 2015 the OECD held a public discussion on action 14 of the base erosion and profit shifting (BEPS) action plan on how to make dispute resolution mechanisms more effective. The Chair of the Focus Group on Dispute Resolution presented to
See MoreOECD Holds Public Meeting on the Prevention of Treaty Abuse
On 22 January 2015 the OECD held a public consultation meeting to discuss the base erosion and profit shifting (BEPS) action 6 on the prevention of tax treaty abuse. The issue as presented in the OECD’s discussion draft on this issue and the
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 MoreSingapore: New Revised Transfer Pricing Guidelines for 2015
The Inland Revenue Authority of Singapore (IRAS) publishes revised transfer pricing (TP) guidelines on 6 January 2015. The 2015 TP Guidelines are generally in line with the OECD Transfer Pricing Guidelines (2010) as well as some relevant areas of
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