OECD releases two discussion drafts on hybrid mismatch arrangements
The two draft reports released on 19 March 2014 by the OECD call for the introduction of both domestic rules and amendments to the OECD Model Tax Convention to neutralize the effect of hybrid mismatch arrangements. The recommendations of the OECD on hybrid mismatch arrangements result from Action 2 of the Action Plan on Base
PwC BEPS webcast: A focus on hybrid mismatch arrangements (27 March)
Date: 27 March 2014 Time: 12:00 pm to 1:00 pm ET Duration: 60 minutes (including Q&A) Click here to register With the 19 March 2014 release of the discussion draft on Action 2 (Neutralise the effects of hybrid mismatch arrangements) of the Base Erosion and Profit Shifting (BEPS) Action Plan, we continue our series of
OECD releases discussion draft on the use of treaty benefits in inappropriate circumstances
This OECD report calls for a very significant rewrite of both the OECD Model Tax Convention and the Commentary, including a US-style Limitation of Benefits (LoB) article as well as a main purpose anti-abuse rule. A variety of other anti-abuse measures are also proposed. If the recommendations are widely adopted, they will undoubtedly reduce treaty
Panel debate on the changing Belgian TP landscape
On 25 February 2014, a flagship event was held reflecting on the changing transfer pricing (TP) environment in Belgium. Two senior representatives from the Belgian administration and one delegate from the Organisation for Economic Cooperation and Development (OECD) shared interesting insights during a panel debate on how they feel that the Base Erosion and Profit Shifting (BEPS) project
An interview with Pascal Saint-Amans on BEPS
Interview with Pascal Saint-Amans on the progress of the OECD on BEPS.
European Parliament’s draft report to the revised Parent Subsidiary Directive
On 28 January 2014, the European Parliament provided its draft report and draft amendments to the European Commission’s proposal for revision of the Parent-Subsidiary Directive. 1. Background On 25 November 2013, the European Commission has proposed certain amendments to the EU Parent-Subsidiary Directive in order to significantly reduce tax fraud/evasion and aggressive tax planning/base erosion and profit
Momentum gathers behind the OECD Action Plan on Base Erosion and Profit Shifting (BEPS)
Download The BEPS Action Plan published by the OECD on 19 July 2013 represents the most ambitious and far-reaching attempt at reform of the global tax system in recent memory. This root and branch review of the global tax rules underpinning the world economy focuses on those cases where profits may be escaping taxation or
OECD’s Action Plan published on Base Erosion and Profit Shifting (BEPS)
Download The publication of the Action Plan and the items listed therein represent a milestone in the ongoing debate on how policy makers and governments will deal with base erosion and profit shifting in the near to long-term future. The desired outcome of the OECD’s BEPS Project is to provide balanced and effective strategies for
