OECD: Technical Guidance for Implementation of the Global Minimum Tax
On 2 February 2023 the Inclusive Framework released technical guidance on implementation by governments of the global minimum tax. The Agreed Administrative Guidance for the Pillar Two GloBE Rules aims to ensure co-ordinated outcomes and greater tax
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OECD: Manual on Multilateral Mutual Agreement Procedures and APAs
On 1 February 2023 the OECD released the Manual on the Handling of Multilateral Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) (the MoMA). Multilateral MAPs and APAs can offer greater tax certainty to both taxpayers
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OECD: Public comments received on the design elements of Amount B under Pillar One
On 30 January 2023 the OECD published the comments received on the design elements of Amount B under Pillar One relating to the simplification of transfer pricing rules. Comments were received from more than sixty businesses, institutes, NGOs and
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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
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OECD: Revised Methodology for the BEPS Action 14 Peer Reviews
On 24 January 2023 the OECD’s Inclusive Framework on base erosion and profit shifting (BEPS) agreed a new assessment methodology for continuing the peer review process under BEPS action 14 to improve tax dispute resolution mechanisms. The
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OECD: Revenue Impact of International Tax Reform
During a live webinar on 18 January 2023 the OECD presented the findings of a new analysis of the estimated impact on tax revenue of the implementation of the two-pillar international tax reform. The new analysis carried out by the OECD indicates
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OECD: Tax certainty for Pillar Two rules
On 20 December 2022 the OECD issued a consultation document on providing tax certainty under the Pillar Two GloBE rules. Comments are invited from interested parties by 3 February 2023. The GloBE rules are to be enacted by each jurisdiction into
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OECD: Peer Review Report on Dispute Resolution Mechanisms in Vietnam
The second stage peer review report on the implementation of the Action 14 minimum standard (making dispute resolution more effective) in Vietnam was published by the OECD’s Inclusive Framework on 13 September 2022. The report notes that
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OECD: Peer Review Report on Dispute Resolution Mechanisms in Thailand
The second stage peer review report on the implementation of the Action 14 minimum standard (making dispute resolution mechanisms more effective) by Thailand was published by the OECD’s Inclusive Framework on 13 September 2022. The report notes
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OECD: Peer Review Report on Dispute Resolution Mechanisms in the UAE
The second stage peer review report on the implementation of the Action 14 minimum standard (making dispute resolution mechanisms more effective) by the United Arab Emirates (UAE) was published by the OECD’s Inclusive Framework on 13 September
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OECD: Peer Review Report on Dispute Resolution Mechanisms in Qatar
The second stage peer review report on the implementation of the Action 14 minimum standard (making dispute resolution mechanisms more effective) by Qatar was published by the OECD’s Inclusive Framework on 13 September 2022. The report notes
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OECD: Peer Review Report on Dispute Resolution Mechanisms in Oman
The second stage peer review report on Oman’s implementation of the minimum standard under BEPS Action 14 (making dispute resolution mechanisms more effective) was published by the OECD’s Inclusive Framework on 13 September 2022. The report
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Australia: Consultation on Multinational Tax Integrity and Tax Transparency
A consultation launched by the Australian government on 5 August 2022 sets out measures that would help to address tax avoidance by multinational groups. Comments are invited by 2 September 2022. The package would implement part of the
See MoreOECD Tax Talk looks at international tax developments
The OECD Tax Talk held on 21 February 2022 provided an updated on important elements of tax work at the OECD. Two-Pillar International Tax Package Public consultations have begun and will cover the various building blocks of Pillar One on a
See MoreSwitzerland: Review of international financial and tax developments in 2021
On 25 January 2022 Switzerland’s State Secretariat for International Financial Matters published its summary for 2021 entitled: Swiss financial and tax centre in 2021: more sustainable, more digital and in good shape despite the pandemic. The
See MoreOECD releases latest edition of the Transfer Pricing Guidelines
On 20 January 2022 the OECD released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The latest edition of the guidelines includes changes made to the 2017 edition by reports issued by
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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