On 18 December 2014 the OECD published discussion drafts on the international VAT/GST guidance and on aspects of the action plan on base erosion and profit shifting.

A discussion draft has been released on two new elements of the OECD International VAT/GST Guidelines. These guidelines are being developed to try to resolve issues relating to double taxation or double non-taxation resulting from differences in national VAT or GST laws. Following the approval of the first three chapters of these guidelines earlier in 2014 the discussion draft is inviting comments on the place of taxation of business to consumer supplies of services and intangible assets and on provisions that will support the application of the VAT guidelines in practice. Comments are invited from interested parties by 20 February 2015.

A discussion draft on action 4 of the BEPS action plan has been released for comment. Action 4 of the BEPS Action Plan is concerned with looking at best practice in formulating rules preventing base erosion and profit shifting using interest or other types of financial payment that in practice give a return that is effectively equivalent to interest. The discussion draft lays out some options that can be considered for arriving at the best practice in this area, and sets out some issues on which it requires input from interested parties. Comments are invited from relevant parties by 6 February 2015 and a public consultation on the issue is planned for 17 February 2015.

A discussion draft on Action 14 of the BEPS action plan on how to make dispute resolution processes more effective was also published for discussion. The problems to be overcome include the exclusion from the mutual agreement procedure article of an arbitration provision except in a few treaties, and the denial of access to the mutual agreement procedure or arbitration in some cases. The deadline for comments from interested parties is 16 January 2015 and there is a public consultation on this issue planned for 23 January 2015.