OECD: Secretary General’s Tax Report to G20 Finance Ministers
On 19 February 2024 the OECD published the Secretary General’s tax report to the G20 Finance Ministers and Central Bank Governors for their meeting of February 2024. The report covered important international tax developments since their previous
See MoreOECD: Comments Received on Proposed Guidance on Pricing of Lithium
On 26 February 2024 the OECD published the responses received on the proposed guidance to support developing countries in addressing risks of base erosion and profit shifting in pricing lithium. Comments were received from eleven government and
See MoreUN: Committee Discusses Terms of Reference for Framework Convention on Tax
On 20 February 2024 the first meeting took place of the Ad Hoc Committee to draft terms of reference for a UN Framework Convention on International Tax Cooperation. The Committee was established by UN Resolution 78/230 of 22 December 2023. It aims
See MoreOECD: Report on the Simplified and Streamlined Approach Under Amount B
On 19 February 2024 the OECD/G20 Inclusive Framework released the report on Amount B of Pillar One, following a previous consultation. The report sets out how jurisdictions can choose to apply the simplified and streamlined approach to qualifying
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OECD releases ICAP statistics
On 29 January 2024 the OECD released the first aggregated statistics from the Forum on Tax Administration’s International Compliance Assurance Programme (ICAP). ICAP The ICAP is a voluntary risk assessment and assurance program whose
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Russia: MOF publishes tax policy plans for 2024
On 2 November 2023, the Ministry of Finance in Russia released a statement regarding the tax policy proposals announced by State Secretary and Deputy Minister of Finance, Alexey Sazanov, during a recent event hosted by the B1 company. The statement
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OECD: Guidance on Transfer Pricing Issues for Bauxite
Following the completion of a previous consultation, on 6 November 2023 the OECD published a toolkit with the title Determining the price of minerals: A Transfer Pricing Framework – Schedule A: Bauxite. This toolkit follows on from the publication
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OECD: Practice Note on Transfer Pricing for Minerals
On 6 November 2023 the OECD published the final version of a practice note with the title Determining the price of minerals: A Transfer Pricing Framework. The practice note has been developed after consultation with interested parties with the aim
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OECD: Report to the Meeting of G20 Finance Ministers and Central Bank Governors
The OECD Secretary General’s report to the meeting of G20 Finance Ministers and Central Bank Governors covered the following issues: Two-Pillar International Tax Package The Inclusive Framework has now released the text of the Multilateral
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OECD: Multilateral Convention in Relation to Amount A of Pillar One
On 11 October 2023 the OECD’s Inclusive Framework released the finalised text of a multilateral convention in relation to Amount A of Pillar One, to co-ordinate the implementation of the reallocation of taxing rights to market jurisdictions,
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OECD: Subject to Tax Rule
On 17 July 2023 the OECD published details of the subject to tax rule (STTR) developed by the Inclusive Framework on BEPS as part of Pillar Two of the two-pillar proposals on international tax. The STTR gives jurisdictions the right to “tax
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OECD: Template for GloBE Information Return
On 17 July 2023 the OECD published details of the contents of the GloBE information return (GIR) under Pillar Two. The GIR is designed to collect the information needed by the tax administration to arrive at an appropriate risk assessment and to
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OECD: Consultation on Amount B of Pillar One
On 17 July 2023 the Inclusive Framework issued a consultation document asking for stakeholder input on Amount B under Pillar One. Comments are invited by 1 September 2023. Amount B applies to baseline marketing and distribution activities, which
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OECD Tax Talk Outlines Progress on Two Pillar Proposals
An OECD Tax Talk held on 19 July 2023 summarised recent developments on the two-pillar international tax proposals. Pillar One – MLC The implementation of Pillar One will require a multilateral convention (MLC) to ensure that the
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OECD: Consultation Document on Transfer Pricing Issues for Bauxite
On 10 May 2023 the OECD published a consultation document with the title Determining the price of minerals: A Transfer Pricing Framework – Schedule A: Bauxite. This document follows on from the OECD’s toolkit outlining a transfer pricing
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OECD: Comments received on Draft MLC under Amount A of Pillar One
On 24 January 2023 the OECD published the responses received to the public consultation on the Draft Multilateral Convention (MLC) Provisions on Digital Services Taxes (DSTs) and other Relevant Similar Measures under Amount A of Pillar One. The
See MoreIndia: CBDT notifies the arm’s-length pricing variation limit for 2021-22
On 29 October 2021, the Central Board of Direct Taxes (CBDT) has published Notification No. 124/2021, which provides for a tolerance limit of 1% for wholesalers and 3% in all other cases for the arm’s-length pricing determination in the
See MoreIreland: Revenue updates TP rules for some qualifying companies
On 6 September 2021, the Revenue updated its guidance to assist some qualifying companies in accordance with Section 110 regarding the application of transfer pricing (TP) rules and other issues. Under Section 110, a company be a qualifying one if
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