OECD releases discussion draft on branch mismatch structures
On 22 August 2016, the OECD published, for discussion, recommendations for domestic laws that would neutralise the effect of payments involving certain branch mismatch arrangements. This expansion of the final Base Erosion and Profit Shifting (BEPS) Action 2 paper, Neutralising the Effects of Hybrid Mismatch Arrangements, issued on 5 October 2015, adds even more complexity
OECD releases discussion draft on interest deductions in banking, insurance sectors
On 28 July the OECD released a discussion draft relating to deductions for interest in the banking and insurance sectors. This is part of the ongoing work for BEPS Action 4, Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, which was released as a final report in October 2015. The discussion draft does
OECD releases public discussion draft on the multilateral instrument to implement the tax treaty related BEPS measures and asks the public for input
On 31 May 2016, the OECD released its public discussion draft on Action 15 (Development of a Multilateral Instrument to Implement the Tax Treaty related BEPS Measures) of the BEPS Action Plan. Action 15 of the OECD’s BEPS Action Plan called for the development of a multilateral instrument in order to allow countries to swiftly amend their
European Commission proposes an EU Directive on public Country-by-Country reporting
As already referred to in our newsflash of 13 April 2016, the European Commission has developed a proposal for a directive which, if approved by the European Parliament and Council of Ministers, will require public country-by-country reporting (CbCR) of tax and other financial data by large companies in the European Union (EU). The proposed directive will amend the existing
Belgian Minister of Finance sheds light on implementation of BEPS related measures
The Belgian Minister of Finance has just shared new insights on how Belgium will be addressing the outcome of the OECD/G20 project in relation to Base Erosion and Profit Shifting (“BEPS”). He opted to do so via the “Plan to combat tax fraud”. The title of his policy note is misleading since the document covers,
Aligning transfer pricing outcomes with value creation – Revised chapters I, II, VI and VII of the OECD Transfer Pricing Guidelines
On 5 October 2015, the OECD presented its final package of Base Erosion and Profit Shifting (BEPS) measures for a comprehensive, coherent, and co-ordinated reform of the international tax rules. The package was endorsed by the G20 Finance Ministers at their meeting on 8 October 2015, in Lima, Peru. This final package (referred to below
OECD recommendations on BEPS proposals for G20 and wider take-up
On 5 October 2015, multinational enterprises (“MNEs”) received final recommendations from the OECD’s base erosion and profit shifting (“BEPS”) project. This week, the G20 Finance Ministers are likely to agree on these OECD recommended changes to the international tax rules and to implementation plans. A number of non-G20 countries have also been involved in work
OECD is heading toward consensus on interest limitation rules
The OECD and country representatives of the OECD Working Party 11 (‘WP11’) are likely to recommend in the BEPS action plan that local interest limitation rules should focus primarily on an interest/EBITDA cap, whereby countries may set the cap within certain boundaries (30% and 10% likely to be put forward as upper and lower limits). As