European 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 MoreWTO Launches Process to Agree Doha Programme
A meeting was held on 21 January 2015 at which the Director General of the World Trade Organization (WTO) began a new consultation process aimed at agreeing on a programme of work to discuss the remaining Doha Development Agenda issues by July 2015.
See MoreOECD Publishes Comments on Transfer Pricing for Low Value Adding Intragroup Services
Intragroup services would include centralized services such as administration, accounting, legal, computer, staff matters and training, which are all considered to be intragroup services. Arm’s length charge Having determined that the services
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
See MoreSingapore: Publishes e-Tax Guide on Transfer Pricing
The Inland Revenue Authority of Singapore (IRAS) has releases second edition of Transfer Pricing Guidelines on January 6, 2015. The e-Tax guide is separated into three main parts and it discusses ways to resolve transfer pricing disputes. It also
See MoreGCC: The International Monetary Fund (IMF) Recommends Diversifying Tax Bases of the States of Gulf Cooperation Council
The International Monetary Fund (IMF) has recommended diversifying tax bases of the states of Gulf Cooperation Council (GCC). It wants GCC to diversify the tax bases from their heavy reliance on oil revenues. The heavy reliance on oil revenue can
See MoreOECD Publishes Information on Revenue Statistics for 2014
The Revenue Statistics for 2014 published by the OECD on 10 December 2014 show that tax revenue collection in the member countries of the OECD has risen back towards the levels prevailing before the financial crisis. The composition of the tax
See MoreOECD : Discussion Draft on Prevention of Treaty Benefits
On 21 November 2014 the OECD released a discussion draft in respect of follow-up work on Action 6 of the action plan on base erosion and profit shifting (BEPS) in respect of preventing the granting of tax treaty benefits in certain circumstances.
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: Discussion Draft on Low Value-Adding Services
The OECD issued a discussion draft on 3 November 2014 in connection with Action 10 of the BEPS project. This relates to modifications to the OECD Transfer Pricing Guidelines in respect of low value adding intra-group services. The discussion draft
See MoreOECD Strategy for Developing Country Involvement in BEPS
The OECD/G20 project on base erosion and profit shifting is important not just to developed countries but to the developing countries which rely on corporate income tax collected from large companies, including multinationals, to fund their
See MoreWTO Report Shows a Rise in Restrictive Trade Measures
A report prepared by the World Trade Organization (WTO) for the G20 and issued on 6 November 2014 indicates that despite undertakings to roll back restrictive trade measures these are still on the rise in the G20 economies. Restrictive measures have
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