OECD releases model documents for implementing BEPS country-by-country reporting
On 8 June 2015, the OECD released a “Country-by-Country Reporting Implementation Package”. The package includes model legislation the OECD suggests could be used by countries to mandate filing of country-by-country reports (“CbCRs”). The model legislation does not attempt to address the filing of the so-called master file or local file reports. The key takeaway is
Revised OECD Discussion Draft on Treaty Abuse published
On Friday, 22 May 2015, the OECD issued a Revised Discussion Draft on BEPS Action 6: Prevention of Treaty Abuse (the RDD). The RDD includes a simplified Limitation on Benefits (LOB) Article for inclusion in the OECD Model Income Tax Convention and provides ‘conclusions and proposals’ on 20 targeted issues. Most of the proposals are
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 The earlier OECD proposals, which set out alternative approaches to a number of significant PE issues, have been replaced by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
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
EU PSD – Council adopts anti-abuse clause
In a press release of 27 January 2015, the Council has disclosed its amendments to the EU Parent-Subsidiary Directive (PSD) (2011/96/EU). Objective of the amendments The Council amended the PSD, adding a binding anti-abuse clause to prevent tax avoidance and aggressive tax planning by corporate groups. The aim is to stop the PSD from being misused for tax avoidance and to
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 recommendations on BEPS 2014 deliverables: Few surprises, but no let-up
As indicated in a newspost earlier this week, the BEPS deliverables for the September 2014 deadline have been published on 16 September 2014 and are available on the OECD website. Please find herewith a link to a summary PwC Bulletin in this respect, highlighting the key take-aways of the reports.