OECD Issues BEPS Documents on Monitoring Mutual Agreement Procedures under Action 14
Action 14 of the OECD project on base erosion and profit shifting (BEPS) was concerned with making dispute resolution procedures more effective. The final report on Action 14 approved by G20 finance ministers in October 2015 outlined the minimum
See MoreNew Zealand: Implementation of BEPS Action 2-hybrid mismatch
The government of New Zealand released a consultative discussion document on 6 September 2016 containing proposals for addressing hybrid mismatch arrangements. The document proposes that New Zealand adopts the 2015 OECD recommendations on hybrid
See MoreSweden: Transfer pricing guidance updated with BEPS
The tax authorities issued an updated version of the Swedish Transfer Pricing guidance on July 2, 2016. The guidance has been updated with the final report on aligning Transfer Pricing outcomes with value creation (Actions 8-10) of the Action Plan
See MoreOECD: Addressing BEPS involving interest in the banking and insurance sectors
On 28 July 2016 the OECD issued a discussion draft outlining approaches to combating base erosion and profit shifting (BEPS) involving interest in the banking and insurance sectors. This is part of further work following the final report on BEPS
See MoreOECD: Report to G20 finance ministers
On 26 July 2016 the OECD published on its website the report prepared for the meeting of the G20 finance ministers held on 23 and 24 July 2016. The report contains updates on progress on the implementation of the recommendations of the reports on
See MoreOECD: Conforming amendments to guidelines on business restructurings
On 4 July 2016 the OECD published a document for public review containing the conforming amendments to Chapter IX of the OECD Guidelines (business restructurings) following the changes made to other parts of the Guidelines as a result of the final
See MoreOECD: Revised guidance on profit splits
On 4 July 2016 the OECD released a consultation document containing revised guidance on profit splits. This is part of the follow-up work on BEPS actions 8 to 10 in relation to assuring that transfer pricing outcomes are in line with value creation.
See MoreOECD: Discussion draft on attribution of profits to permanent establishments
On 4 July 2016 the OECD published a discussion draft on additional guidance on the attribution of profits to permanent establishments, as part of the follow-up to the work on base erosion and profit shifting (BEPS). Comments are invited from
See MoreOECD: Kyoto meeting takes forward the new inclusive framework for tackling BEPS
An initial meeting was held in Kyoto on 30 June and 1 July 2016 to take forward the new inclusive framework for tackling base erosion and profit shifting (BEPS). Delegates representing more than 80 countries at various stages of development
See MoreOECD: Guidance on implementation of country by country reporting
On 29 June 2016 the OECD published guidance on aspects of country by country (CbC) reporting. The guidance covers the following aspects: Transitional filing options for multinationals voluntarily filing in the parent jurisdiction; The
See MoreOECD releases request for input on multilateral instrument to implement tax treaty related BEPS measures
On 31 May 2016 the OECD released a request for input inviting comments from interested parties on the multilateral instrument to implement the tax treaty related measures in the OECD/G20 action plan on base erosion and profit shifting (BEPS). Input
See MoreAustria: Publishes Transfer Pricing Documentation draft Law
The Austrian Ministry of Finance (MoF) published the draft of the European Union (EU) Tax Amendment Act 2016 on 9 May 2016. The focus of this proposal is the draft of the new Austrian Transfer Pricing Documentation Law (TPDL). The new law serves as
See MoreAxiom Groupe conference on Transfer Pricing Excellence
The Axiom Groupe conference on Transfer Pricing Excellence was held in Barcelona on 19 and 20 May 2016. The conference included a workshop from the World Bank group. Some of the important issues coming out of the sessions are summarized
See MoreOECD: Forum on Tax Administration discusses international tax cooperation
Participants from forty-nine delegations including regional and international tax organizations attended the Tenth Meeting of the OECD Forum on Tax Administration from 11 to 13 May 2016. The delegates confirmed their commitment to continuing
See MoreOECD: Multilateral competent authority agreement signed by China and India
On 12 May 2016 six countries including China and India signed the multilateral competent authority agreement for the exchange of country by country (CbC) reports. The other countries signing the agreement on 12 May were Canada, Iceland, Israel and
See MoreDenmark: Publishes new transfer pricing documentation guidelines
The Danish Ministry of Taxation issued two Orders : BEK nos. 401 and 402, on 28 April 2016, concerning transfer pricing documentation. The new documentation guidelines BEK no. 402, which will replace the previous guidelines of 24 January 2006 (BEK
See MorePlatform for Collaboration on Tax set up by OECD, IMF, UN and World Bank
On 19 April 2016 the OECD, IMF, World Bank and UN announced the creation of a Platform for Collaboration on Tax. The Platform will intensify cooperation between these bodies as well as hosting regular consultations on the design and implementation
See MoreEU proposals on country by country reporting
In the Action Plan on a Fairer Corporate Tax System issued in March 2015 the European Commission proposed to implement in the European Union (EU) the proposals under Action 13 of the OECD’s action plan on base erosion and profit shifting (BEPS).
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