OECD Publishes 2014 Update to Model Tax Convention
The OECD Council approved the 2014 Update to the OECD Model Tax Convention (the 2014 Update) on 15 July 2014. The 2014 Update was already approved by the Committee on Fiscal Affairs on 26 June 2014. The 2014 Update can be found here. The 2014 Update mainly reflects the work that was carried out by the OECD
EU Member States agree to amend the EU PSD to tackle hybrid loan arrangements
On 20 June 2014, the EU’s Council of Economic and Finance (ECOFIN) Ministers took place in Luxembourg. ECOFIN agreed amongst others on the amendments to the Parent-Subsidiary directive (PSD) and adopted conclusions on the report of the Code of Conduct Group on Business Taxation. Proposed amendments on the Parent – Subsidiary directive The ECOFIN agreed
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
The OECD’s public consultation on transfer pricing documentation and country-by-country reporting on 19 May
The OECD will hold a public consultation on the discussion draft on transfer pricing documentation and country-by-country reporting on 19 May 2014 at the OECD Conference Centre in Paris, France. The public consultation will be broadcast live on the Internet and can be accessed on line. No advance registration will be required for Internet access. Persons wishing
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
BEPS Webcast – A focus on the digital economy, 17 April 2014
The OECD recently released its discussion draft focused on the digital economy as part of the Base Erosion and Profit Shifting (BEPS) Action Plan. In response to this draft, we will hold another webcast in our series of BEPS related webcasts. Please join us on 17 April where we will review the latest discussion draft
BEPS webcast series: A focus on treaty benefits
The OECD recently released its discussion draft on the use of treaty benefits in inappropriate circumstances. In response to this draft, part of the Base Erosion and Profit Shifting (BEPS) Action Plan, we will hold another webcast in our series, exploring the OECD’s Coordinated Action Plan on BEPS. Date: 7 April 2014 Time: 12:00 pm
OECD discussion drafts may impact private equity arrangements
The OECD released draft reports between 14 March 2014, and 19 March 2014, as part of the Base Erosion and Profit Shifting program that call for substantial changes to domestic tax rules, double taxation agreements, and amendments to the OECD Model Tax Convention and Commentary. If the recommendations are widely adopted, they will have a
