Revised OECD Discussion Draft on permanent establishments – PwC Newsflash published
As mentioned in the news alert published on 18 May 2015, the OECD issued a revised discussion draft on preventing the artificial avoidance of permanent establishment (‘PE’) status under Action 7 of the BEPS Action Plan. The earlier OECD proposals, which set out alternative approaches to a number of significant PE issues, have been replaced by
Revised OECD Discussion Draft on permanent establishments published
On 15 May 2015, the OECD issued a revised discussion draft on preventing the artificial avoidance of permanent establishment (‘PE’) status under Action 7 of the BEPS action plan. The proposals in this revised discussion draft (which the OECD calls the ‘new discussion draft’ or ‘second discussion draft’) were all included among the options that appeared
OECD publishes Discussion Draft on cost contribution arrangements
On 29 April 2015, the OECD issued a Discussion Draft on the transfer pricing aspects of cost contribution arrangements (‘CCAs’) under Action 8 of the BEPS action plan. The Draft proposes fundamental modifications to Chapter VIII of the OECD Transfer Pricing Guidelines: With respect to measuring the value of contributions to CCAs and the tax
Revised OECD BEPS timetable
The OECD has published a revised OECD timetable for stakeholders’ input, with the dates when new discussion drafts will be published and public consultations will be held in relation to the 2015 Base Erosion and Profit Shifting (BEPS) outputs. The revised OECD timetable can be consulted here. During March and April 2015, the OECD released
Belgium considers introducing mandatory transfer pricing documentation following the outcome of the BEPS Action Plan
The Belgian Minister of Finance, Johan Van Overtveldt, shared some new insights about the government’s ambitions in the area of transfer pricing as part of his reply to a parliamentary question on Wednesday 11 March 2015 (CRIV 54 COM 111 –Parliamentary Question no. 2774). The Minister referred to the OECD project in relation to Base Erosion
UK’s ‘Diverted Profits Tax’ proposes a 25% tax rate for taxpayers but leaves open questions
Background On 10 December 2014 HM Revenue & Customs (HMRC) released the diverted profits tax (DPT) provisions within its draft Finance Bill 2015. Upon initial review, the new rules could affect many more companies than one might have anticipated. Scope The DPT is a new tax, with a 25% rate on profits that are considered
BEPS Project: Time to take a closer look at treasury and intercompany financing
OECD Base Erosion & Profit Shifting (BEPS) Project: Time to take a closer look at treasury and intercompany financing Just before the New Year’s break, the OECD issued new discussion drafts in the context of the so-called ‘Base Erosion & Profit Shifting’ project as mandated by the G20, better known as ‘BEPS’. They are particularly
UK states that OECD agrees on substantial activity level required to benefit from preferential IP regimes
The Governments of Germany and the United Kingdom (UK) have, on 11 November 2014, shown their commitment to ensuring that the G20/OECD Base Erosion and Profit Shifting (BEPS) project is successfully concluded by the end of 2015. As such, they have issued a joint statement on 11 November, so as to take forward the pending
