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OECD seeks input on new tax rules requiring disclosure of CRS avoidance arrangements and offshore structures

Today the OECD is releasing a consultation document seeking stakeholder input on model mandatory disclosure rules. The model rules target promoters and service providers with a material involvement in the design, marketing or implementation of a CRS avoidance arrangements or offshore structure. They would require such intermediaries to disclose information on the scheme to their local tax authority.




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OECD releases second round of peer reviews on implementation of BEPS minimum standards on improving tax dispute resolution mechanisms

As part of continuing efforts to improve the international tax framework and tax certainty, the OECD has released the second round of analyses of individual country efforts to improve dispute resolution mechanisms. These seven peer review reports represent the second round of stage 1 evaluations of how countries are implementing new minimum standards agreed in the OECD/G20 BEPS Project.




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Qatar signs tax co-operation agreement to enable automatic sharing of country-by-country information (BEPS Action 13)

As part of continuing efforts to boost transparency by multinational enterprises (MNEs), Qatar has signed the Multilateral Competent Authority Agreement for Country-by-Country Reporting (CbC MCAA), bringing the total number of signatories to 68.




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Further progress made in implementation of BEPS measures against tax treaty abuse

Today, Jersey deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("multilateral convention") with the OECD. Subsequently, on 20 December, Curaçao joined the multilateral convention.




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Over 2600 bilateral relationships in place for the exchange of CRS information

The Common Reporting Standard (CRS), which is the basis for the automatic annual exchange of information on offshore financial accounts to the tax authorities of the residence country of account holders. At present, over 100 jurisdictions have publicly committed to implement the CRS, with half of them having started the exchange of CRS information in September and a further 53 set to follow in 2018.




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BEPS Action 13: Jurisdictions implement final regulations for first filings of CbC Reports, with over 1400 bilateral relationships now in place for the automatic exchange of CbC information

Today, a further important step was taken to implement Country-by-Country (CbC) Reporting in accordance with the BEPS Action 13 minimum standard, through activations of automatic exchange relationships under the Multilateral Competent Authority Agreement on the Exchange of CbC Reports ("the CbC MCAA").




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Public comments received on new tax rules requiring disclosure of CRS avoidance arrangements and offshore structures

On 11 December 2017, interested parties were invited to provide comments on a discussion draft on model mandatory disclosure rules. The model rules are intended to target promoters and service providers with a material involvement in the design, marketing or implementation of CRS avoidance arrangements or offshore structures.




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Eight FTA members kick off multilateral tax risk assurance programme to provide early certainty for tax administrations and MNEs

A pilot of a new FTA programme for the multilateral risk assessment of large MNE groups was launched at an event today in Washington DC, hosted by the Internal Revenue Service.




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Governments should make better use of energy taxation to address climate change

Taxes are effective at cutting harmful emissions from energy use, but governments could make better use of them. Greater reliance on energy taxation is needed to strengthen efforts to tackle the principal source of both greenhouse gas emissions and air pollution, according to a new OECD report.




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OECD releases consultation document on misuse of residence by investment schemes to circumvent the Common Reporting Standard

Public input is sought both to obtain further evidence on the misuse of CBI/RBI schemes and on effective ways for preventing abuse.




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OECD releases third round of peer reviews on implementation of BEPS minimum standards on improving tax dispute resolution mechanisms and calls for taxpayer input for the fifth round

As the BEPS Action 14 continues its efforts to make dispute resolution more timely, effective and efficient, eight more peer review reports have been released today. These eight reports highlight how well jurisdictions are implementing the Action 14 minimum standard as agreed to in the OECD/G20 BEPS Project.




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OECD releases additional guidance on the attribution of profits to a permanent establishment under BEPS Action 7

The additional guidance resulting sets out high-level general principles, which countries agree are relevant and applicable in attributing profits to PEs in accordance with applicable treaty provisions. It also provides examples on the attribution of profits to certain types of PEs arising from the changes to the PE definition under BEPS Action 7.




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Global network for the automatic exchange of offshore account information continues to grow; OECD releases new edition of the CRS Implementation Handbook

Today, the OECD published a new set of bilateral exchange relationships established under the Common Reporting Standard Multilateral Competent Authority Agreement (CRS MCAA) which for the first time includes activations by Panama. The OECD also released the second edition of the Common Reporting Standard Implementation Handbook.




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OECD releases 14 additional country profiles containing key aspects of transfer pricing legislation

The OECD has published 14 new and 2 updated transfer pricing country profiles, reflecting the current transfer pricing legislation and practices of participating countries. The country profiles, which are now available for 44 countries, contain up-to-date and harmonised information on key aspects of transfer pricing legislation, provided by countries themselves.




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Better design of taxes on personal savings and wealth is needed to support inclusive growth

The taxation of personal savings and wealth varies widely, offering governments significant scope for tax reforms that simultaneously improve both the efficiency and fairness of their tax systems, according to two new OECD reports.




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Public comments received on misuse of residence by investment schemes to circumvent the Common Reporting Standard

The consultation document assessed how these schemes are used in an attempt to circumvent the CRS; identified the types of schemes that present a high risk of abuse; reminded stakeholders of the importance of correctly applying relevant CRS due diligence procedures in order to help prevent such abuse; and explained next steps the OECD will undertake to further address the issue, assisted by public input.




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OECD and IGF invite comments on a draft practice note that will help developing countries address profit shifting from their mining sectors via excessive interest deductions

Building on BEPS Action 4, this practice note has been prepared by the OECD under a programme of co-operation with the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF), to help guide tax officials on how to strengthen their defences against BEPS. Deadline for comment: 18 May 2018.




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OECD addresses the misuse of residence/citizenship by investment schemes

Today’s revelations from the “Daphne Project” on the Maltese residence and citizenship by investment schemes underline the crucial importance of the the OECD’s work to ensure that the integrity of the OECD/G20 Common Reporting Standard (CRS) is preserved and that any circumvention is detected and addressed.




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Workers in OECD countries pay one quarter of wages in taxes

Workers in OECD countries paid just over a quarter of their gross wages in tax on average in 2017, with just over half of countries seeing small increases in the personal average tax rate, according to a new OECD report.




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OECD invites public comments on the scope of the future revision of Chapter IV (administrative approaches) and Chapter VII (intra-group services) of the Transfer Pricing Guidelines

Public comments are invited on the future revision of Chapter IV, “Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes” of the Transfer Pricing Guidelines, and the future revision of Chapter VII, “Special Considerations for Intra-Group Services”, of the Transfer Pricing Guidelines.




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OECD releases decisions on 11 preferential regimes of BEPS Inclusive Framework Members

Governments are continuing to make swift progress in bringing their preferential tax regimes in compliance with the OECD/G20 BEPS standards to improve the international tax framework. Today the Inclusive Framework released the updates to the results for preferential regime reviews conducted by the Forum on Harmful Tax Practices (FHTP) in connection with BEPS Action 5.




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Serbia deposits its instrument of ratification for the Multilateral BEPS Convention

Today, Serbia deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (multilateral convention or MLI) with the OECD’s Secretary-General, Angel Gurría, therewith underlining its strong commitment to prevent the abuse of tax treaties and base erosion and profit shifting (BEPS) by multinational enterprises.




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OECD releases new guidance on the application of the approach to hard-to-value intangibles and the transactional profit split method under BEPS Actions 8-10

Today, the OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method under BEPS Action 10.




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OECD launches largest source of comparable tax revenue data

A new database providing detailed and comparable tax revenue information for 80 countries around the world – and which and will expand to cover more than 90 countries by the end of 2018 – was unveiled today during the 5th plenary meeting of the Inclusive Framework on BEPS, held in Lima, Peru.




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Public comments received on the scope of the future revisions of Chapter IV (Administrative Approaches) and Chapter VII (Intra-group services) of the Transfer Pricing Guidelines

Public comments received on the scope of the future revisions of Chapter IV (Administrative Approaches) and Chapter VII (Intra-group services) of the Transfer Pricing Guidelines




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Former Yugoslav Republic of Macedonia signs the multilateral Convention on Mutual Administrative Assistance in Tax Matters

The Former Yugoslav Republic of Macedonia today signed the multilateral Convention on Mutual Administrative Assistance in Tax Matters, making it the 124th jurisdiction to join the world’s leading instrument for boosting transparency and combating cross-border tax evasion.




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OECD releases BEPS discussion draft on the transfer pricing aspects of financial transactions

Public comments are invited on a discussion draft on financial transactions, which deals with follow-up work in relation to Actions 8-10 ("Assure that transfer pricing outcomes are in line with value creation") of the BEPS Action Plan.




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Major enlargement of the global network for the automatic exchange of offshore account information as over 100 jurisdictions get ready for exchanges

Today, the OECD published a new set of bilateral exchange relationships established under the Common Reporting Standard Multilateral Competent Authority Agreement (CRS MCAA), bringing the total number of relationships to over 3200, an increase of more than 500 since April of this year.




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Platform for Collaboration on Tax invites final comments on a revised version of its report on the “Taxation of Offshore Indirect Transfers of Assets”

The Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN and World Bank Group – has undertaken, at the request of the G20, the development of a series of “toolkit” reports to help guide developing countries in the implementation of policy options for issues in international taxation of greatest relevance to these countries.




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OECD, government officials and parliamentarians discuss developments in international tax co-operation at high-level meeting in Georgia

Over 70 participants from 20 countries in Europe and Central Asia gathered Georgia for a high-level regional event on Developments in International Tax Co-operation on 17-18 July 2018. Participants discussed policy responses to fighting tax evasion and avoidance, as well as the opportunities and challenges presented by the practical implementation of international standards on tax transparency and BEPS.




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OECD invites taxpayer input on sixth batch of Dispute Resolution peer reviews (BEPS Action 14)

The OECD is gathering input for the Stage 1 peer reviews of Argentina, Chile, Colombia, Croatia, India, Latvia, Lithuania and South Africa, and invites taxpayers to submit input on specific issues relating to access to MAP, clarity and availability of MAP guidance and the timely implementation of MAP agreements for each of these jurisdictions using the taxpayer input questionnaire.




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Antigua and Barbuda becomes the 125th jurisdiction to join the most powerful multilateral instrument against offshore tax evasion and avoidance

Antigua and Barbuda today signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. It is the 125th jurisdiction to join the Convention.




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The Former Yugoslav Republic of Macedonia (FYROM) joins the Inclusive Framework on BEPS

The Former Yugoslav Republic of Macedonia (FYROM) has become the 117th jurisdiction to join the Inclusive Framework on BEPS (“IF”).




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OECD releases fourth round of BEPS Action 14 peer review reports on improving tax dispute resolution mechanisms

The work on BEPS Action 14 continues with today’s publication of the fourth round of stage 1 peer review reports. Each report assesses a country’s efforts to implement the Action 14 minimum standard as agreed to under the OECD/G20 BEPS Project.




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Simplified registration and collection mechanisms for taxpayers that are not located in the jurisdiction of taxation

This paper reviews and evaluates the efficacy of simplified tax registration and collection mechanisms for securing compliance of taxpayers over which the jurisdiction with taxing rights has limited or no authority to effectively enforce a tax collection or other compliance obligation.




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OECD releases seven new transfer pricing country profiles and an update of a previously-released profile

The OECD has published new transfer pricing country profiles for Costa Rica, Greece, Republic of Korea, Panama, Seychelles, South Africa and Turkey. In addition, it has also updated the information contained in Singapore’s profile. The country profiles are now available for 52 countries.




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Public comments received on BEPS discussion draft on the transfer pricing aspects of financial transactions

On 3 July 2018, interested parties were invited to provide comments on a discussion draft on financial transactions, which deals with follow-up work in relation to Actions 8-10 (“Assure that transfer pricing outcomes are in line with value creation”) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the public comments received.




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OECD and SAT hold joint workshop on the experience of country-by-country reporting of tax information

Tax officials from 21 jurisdictions met this week in Yangzhou, China, to share experiences from the first year of country-by-country reporting and explore how information can be used most effectively in the tax risk assessment of MNE groups. The workshop also included representatives of large MNE groups headquartered or with major operations in China and the Asia-Pacific region.




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Australia, France, Japan and Slovak Republic deposit their instrument of ratification or acceptance for the Multilateral BEPS Convention

Australia, France, Japan and the Slovak Republic have deposited their instrument of ratification or acceptance for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting with the OECD’s Secretary-General, therewith underlining their strong commitment to prevent the abuse of tax treaties and BEPS by multinational enterprises.




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OECD and IGF release first set of practice notes for developing countries on BEPS risks in mining

The OECD’s Centre for Tax Policy and Administration and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) are collaborating to address some of the challenges developing countries face in raising revenue from their mining sectors. Under this partnership, a series of practice notes and tools are being developed for governments.




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Jurisdictions take action to address the potential misuse of RBI/CBI schemes for CRS-circumvention purposes

The OECD is pleased to announce that jurisdictions are taking further action to prevent the misuse of RBI/CBI schemes by account holders by putting in place an exchange of information mechanism that will ensure that the information on applicants of RBI/CBI schemes will be made available to their jurisdiction(s) of tax residence.




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OECD and World Bank call for whole-of-government approach to combating tax evasion and corruption

Countries must step up work to ensure that tax authorities and anti-corruption authorities can effectively co-operate in the fight against tax evasion, bribery, and other forms of corruption, according to a joint OECD/World Bank report.




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OECD and tax officials from Eastern Europe and Central Asia discuss BEPS implementation in Armenia

Over 60 delegates from 16 countries, international and regional organisations, business, civil society and academia gathered in Yerevan, Armenia on 7 - 9 November 2018 for a regional meeting of the Inclusive Framework on BEPS in Eastern Europe and Central Asia.




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11th Meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes, 20-22 November 2018, in Punta del Este, Uruguay

Global cooperation to fight tax evasion and avoidance has grown rapidly over the past few years. Tax Transparency and Exchange of Information between tax authorities about financial assets and activities of their taxpayers abroad has proved to be a valuable tool in this fight.




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OECD releases guidance on Synthesised texts for providing clarity on the impact of the Multilateral Instrument

This new guidance presents a clear overview of the modifications to tax treaties resulting from the Multilateral BEPS Convention which entered into force on 1 July 2018. A Secretariat note, also released today, clarifies the entry into effect rules for tax treaties of jurisdictions that deposited their ratification instruments last September.




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OECD invites taxpayer input on seventh batch of Dispute Resolution peer reviews

The OECD is gathering input for the Stage 1 peer reviews of Brazil, Bulgaria, China (People's Republic of), Hong Kong (China), Indonesia, Papua New Guinea, Russian Federation and Saudi Arabia, and invites taxpayers to submit input on specific issues relating to access to MAP, clarity and availability of MAP guidance and the timely implementation of MAP agreements for each of these jurisdictions using the taxpayer input questionnaire.




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Global Forum on Tax Transparency marks a dramatic shift in the fight against tax evasion with the widespread commencement of the automatic exchange of financial information

The Global Forum held its annual meeting in Uruguay on 20-22 November, bringing together 220 delegates from 84 jurisdictions and 12 International organisations to strengthen further the international community’s fight against tax evasion. The meeting marked the widespread rollout of automatic exchange of financial account of information.




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Jamaica deposits instrument of ratification for the multilateral Convention on Mutual Administrative Assistance in Tax Matters

The Convention will enter into force for Jamaica on 1 March 2019 and will generally apply from 1 January 2020, although it may apply for earlier periods between signatories if agreed to and applies in relation to any period regarding criminal matters.




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The Bahamas signs MCAA to activate automatic exchange of information for country-by-country reporting

The purpose of the CbC MCAA is to set forth rules and procedures as may be necessary for Competent Authorities of jurisdictions implementing BEPS Action 13 to automatically exchange CbC Reports prepared by the Reporting Entity of an MNE Group and filed on an annual basis with the tax authorities of the jurisdiction of tax residence of that entity with the tax authorities of all jurisdictions in which the MNE Group operates.




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Belize signs landmark agreement to strengthen its tax treaties and Monaco deposits its instrument of ratification for the Multilateral BEPS Convention

Belize has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS, becoming the 86th jurisdiction to join the Convention, which now covers almost 1500 bilateral tax treaties. Yesterday, Monaco deposited its instrument of ratification for the Convention with the OECD’s Secretary-General.