G20 Leaders’ Declaration
The Declaration issued by the G20 leaders at their meeting on 9 and 10 September 2023 included the following points: Global Economic Situation The Declaration noted the recent global crises that have posed challenges to long-term growth and
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OECD: Report to the G20 leaders meeting of September 2023
The tax report by the OECD Secretary General to the meeting of G20 leaders on 9 to 10 September 2023 outlines the latest international tax developments in international tax reform, including the work on the two-pillar international tax plan;
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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: Outcome Statement on the Two Pillar Solution
On 11 July 2023 an Outcome Statement on the two-pillar international tax solution was approved by 138 member jurisdictions of the Inclusive Framework on base erosion and profit shifting. The Outcome Statement summarises the package of deliverables
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OECD Report to the G20 Financial Ministers and Central Bank Governors
On 17 July 2023 the OECD published the report prepared for the meeting of G20 finance ministers and central bank governors held in India on 17 and 18 July 2023. Update on the Two-Pillar International Tax Solution The report noted that on 11
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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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UK: Second Reading of Spring Finance Bill 2023
On 13 June 2023 the UK government published the Tax Information and Impact Notes for government amendments at the report stage of the Spring Finance Bill 2023. The Bill includes the following measures: Multinational Top-up tax: UK adoption of
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IMF: Mining Revenues and Inclusive Development in Guinea
An IMF working paper on Mining Revenues and Inclusive Development in Guinea by A. Badel and R.F. Lyngaas was published on 29 April 2023. The working paper looked at the potential benefits from increasing the taxation of the foreign extractive
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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 Tax Talk Outlines Latest Developments
On 27 February 2023 the OECD gave an update of recent developments in their tax work. G20 Chair’s summary The G20 Chair’s summary following the meeting of G20 finance ministers and central bank governors confirmed that the G20 remains
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OECD Report to the February 2023 Meeting of G20 Finance Ministers
On 24 February 2023 the OECD published its report to the February 2023 meeting of the G20 Finance Ministers and Central Bank Governors. Inclusive Framework The report notes that the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework)
See MoreUK: Research on Taxpayer Experience of the Profit Diversion Compliance Facility
On 7 February 2023 HMRC published the results of research commissioned in order to understand taxpayers’ experience of the Profit Diversion Compliance Facility (PDCF) and Diverted Profits enquiry process. The research was conducted through
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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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