OECD Report on Action 6 – Treaty Abuse
The OECD published a discussion draft in March 2014 on proposals for addressing perceived abuse of tax treaties. The draft recommended extensive changes to the OECD Model Treaty together with suggested domestic law provisions targeted at treaty abuse or abuse of domestic law where the abuse involves application of treaty benefits. It also proposed a
OECD guidance on Transfer Pricing Aspects of Intangibles: Revised Chapters I, II and VI of the OECD Transfer Pricing Guidelines
On 16 September 2014, the OECD published its final and interim revisions in relation to Chapters I, II and VI of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. These revisions have been developed in connection with Action 8 of the Action Plan on Base Erosion and Profit Shifting that is focused
OECD releases BEPS reports following September deadline
The OECD is keeping its word in preparing and delivering on the objectives as they have been set in the BEPS Action Plan. The deliverables for the September 2014 deadline have just been published and are available on the OECD website (link below). The OECD has published 7 reports (Digital Economy, Hybrid Mismatches, Harmful Tax, Treaty Abuse, Intangibles
BEPS: OECD is gearing up towards the September deadlines
The OECD’s Action Plan on Base Erosion and Profit Shifting (BEPS) was published in July 2013 with a view to addressing perceived flaws in international tax rules. The 40-page Action Plan, which was negotiated and drafted with the active participation of the OECD member states, contains 15 separate action points or work streams, some of which are
Upcoming Global OECD BEPS webcasts
In the framework of the upcoming G20 Finance Ministers meeting to be held in Cairns, Australia on 20-21 September 2014, there are two global OECD BEPS webcasts scheduled this month for you in order to guide you through and anticipate on any potential impact on your businesses: BEPS: Global alignment vs national interest?: This first is a live
OECD releases request for input on BEPS Action 11
Background The Action 11 work of the BEPS (base erosion and profit shifting) action plan aims to produce an overview of several different economic analyses of BEPS using different data and methodologies that will give a potential range of the scale (i.e. magnitude of the change in overall tax receipts) and economic impacts (i.e. effects on total
Formal EU State Aid investigation into certain tax rulings
On June 11, 2014, the European Commission opened a formal State Aid investigation procedure into the transfer pricing arrangements and corporate taxation of certain companies in Ireland, the Netherlands and Luxembourg. See this link for more information. Wider inquiry into tax rulings In parallel to these three formal investigations, the Commission will continue its wider inquiry
PwC comments on the Discussion Draft on Transfer Pricing Comparability Data and Developing Countries
PwC has provided the OECD with its comments on the ‘discussion draft on transfer pricing comparability data and developing countries’ on 11 April 2014. PwC agrees with the OECD in that comparability is at the heart of transfer pricing, and that the application of the arm’s length principle often relies on a comparison of the prices charged
