public comment

Public comments received on discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan

On 31 October 2014, the OECD invited comments from interested parties on the discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan. The OECD now publishes the comments received.




public comment

Public comments received on follow-up work on Action 6 (Prevent treaty abuse) of the BEPS Action Plan

On 21 November 2014, the OECD invited comments from interested parties on the discussion draft on Action 6 (Prevent treaty abuse) of the BEPS Action Plan. The OECD now publishes the comments received.




public comment

Public comments received on discussion draft on Action 14 (Make dispute resolution mechanisms more effective) of the BEPS Action Plan

On 18 December 2014, the OECD invited comments from interested parties on the discussion draft on Action 14 (Make dispute resolution mechanisms more effective) of the BEPS Action Plan. The OECD now publishes the comments received.




public comment

Public comments received on discussion draft on Actions 8, 9 and 10 : revisions to Chapter I of the Transfer Pricing Guidelines (Including risk, recharacterisation and special measures) of the BEPS Action Plan

On 19 December 2014, interested parties were invited to comment on the discussion draft on Actions 8, 9 and 10: revisions to Chapter I of the Transfer Pricing Guidelines (Including risk, recharacterisation and special measures) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the comments received.




public comment

Public comments received on the discussion draft on the use of profit splits in the context of global value chains (BEPS Action 10)

On 16 December 2014, the OECD invited comments from interested parties on a discussion draft on the use of profit splits in the context of global value chains. This work relates to Action 10 of the BEPS Action Plan. The OECD is grateful to the commentators for their input, and now publishes the comments received.




public comment

Public comments received on discussion draft on the transfer pricing aspects of cross-border commodity transactions (BEPS Action 10)

On 16 December 2014, the OECD invited comments from interested parties on a discussion draft on the transfer pricing aspects of cross-border commodity transactions. This work relates to Action 10 of the BEPS Action Plan. The OECD is grateful to the commentators for their input, and now publishes the comments received.




public comment

Public comments received on discussion draft on Action 4 (Interest Deductions and Other Financial Payments) of the BEPS Action Plan

On 18 December 2014, interested parties were invited to comment on the discussion draft on Action 4 (Interest Deductions and other Financial Payments) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the comments received.




public comment

Public comments received on discussion drafts of two new elements of the OECD International VAT/GST Guidelines

On 18 December 2014, the OECD invited comments from interested parties on discussion drafts of two new elements of the OECD International VAT/GST Guidelines. These discussion drafts related to (i) the place of taxation of business-to-consumer supplies of services and intangibles (B2C Guidelines) and (ii) provisions to support the application of the Guidelines in practice (Supporting provisions)




public comment

Public comments received on discussion draft on Action 12 (Mandatory Disclosure Rules) of the BEPS Action Plan

On 31 March 2015, interested parties were invited to comment on the discussion draft on Action 12 (Mandatory Disclosure Rules) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the comments received.




public comment

Public comments received on discussion draft on Action 3 (Strengthening CFC Rules) of the BEPS Action Plan

On 3 April 2015, interested parties were invited to comment on the discussion draft on Action 3 (Strengthening CFC Rules) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the comments received.




public comment

Public comments received on discussion draft on BEPS Action 11 (Data Analysis)

On 16 April 2015, interested parties were invited to comment on the discussion draft on Action 11 (Data Analysis) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and is now publishing the comments received.




public comment

Public comments received on revised discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan

On 15 May 2015, interested parties were invited to comment on a revised discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan.




public comment

Public comments received on revised discussion draft on follow-up work on BEPS Action 6 (Prevent treaty abuse)

On 22 May 2015, interested parties were invited to comment on a revised discussion draft which includes proposals on how to deal with the follow-up work on Action 6 (Prevent treaty abuse) of the BEPS Action Plan.




public comment

Public comments received on discussion draft on BEPS Action 8 (Hard-to-value intangibles)

On 4 June 2015, interested parties were invited to comment on a discussion draft on Action 8 (Hard-to-value intangibles) of the BEPS Action Plan.




public comment

Public comments received on discussion draft on the treaty residence of pension funds

On 29/02/2016, interested parties were invited to comment on a discussion draft othat includes proposals for changes to the OECD Model Tax Convention concerning the treaty residence of pension funds. The OECD is grateful to the commentators for their input and now publishes the comments received.




public comment

Public comments received on discussion draft on treaty entitlement of non-CIV funds

On 24 March 2016, comments were invited to the questions included in a consultation document on issues and suggestions on the tax treaty entitlement of non-CIV (Collective Investment Vehicle) funds.




public comment

Public comments received for the discussion draft on the development of a multilateral instrument to implement the tax treaty related BEPS measures

On 31 May 2016, public comments were invited on technical issues identified in a Request for Input related to the development of a multilateral instrument to implement the tax-treaty related BEPS measures. This document compiles the comments received in response to that request for input.




public comment

Public comments received on the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines

On 4 July 2016, interested parties were invited to review the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines, "Transfer Pricing Aspects of Business Restructurings". The OECD is grateful to the commentators for their input and now publishes the comments received.




public comment

Public comments received on the discussion draft on the design and operation of the group ratio rule under BEPS Action 4

OECD publishes comments received on the discussion draft on the elements of the design and operation of the group ratio rule under Action 4.




public comment

Public comments received on the BEPS discussion drafts on the Attribution of Profits to Permanent Establishments and the Revised Guidance on Profit Splits

Public comments have been received on the BEPS discussion drafts on the Attribution of Profits to Permanent Establishments and the Revised Guidance on Profit Splits.




public comment

Public comments received on the discussion draft on approaches to address BEPS involving interest in the banking and insurance sectors under Action 4

The OECD publishes comments received on the discussion draft on approaches to address BEPS involving interest in the banking and insurance sectors under Action 4.




public comment

Public comments received on the discussion draft on branch mismatch structures under Action 2 of the BEPS Action Plan

The OECD publishes the comments received on the discussion draft on branch mismatch structures under Action 2 of the BEPS Action Plan.




public comment

Public comments received on draft examples prepared as part of the follow-up work on the interaction between the treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds

On 6 January 2017, public comments were invited on draft examples prepared as part of the follow-up work on the interaction between the treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds. The OECD is grateful for the input and now publishes a compilation of the comments received.




public comment

Public comments received on the BEPS discussion draft on the Implementation Guidance on Hard-to-Value Intangibles

On 23 May 2017, interested parties were invited to provide comments on a discussion draft that provides guidance on the implementation of the approach to pricing transfers of hard-to-value intangibles described in Chapter VI of the Transfer Pricing Guidelines.




public comment

Public comments received on the draft contents of the 2017 Update to the OECD Model Tax Convention

Public comments received on the draft contents of the 2017 Update to the OECD Model Tax Convention




public comment

Public comments received on BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits

The OECD is publishing the comments received on a discussion draft on the Attribution of Profits to Permanent Establishments (BEPS Action 7) and on a second discussion draft on the Revised Guidance on Profit Splits (BEPS Actions 8-10).




public comment

Public comments received on the tax challenges of digitalisation

On 22 September 2017, interested parties were invited to provide comments on the tax challenges of digitalisation. The OECD is grateful to the commentators for their input and now publishes the public comments received. A public consultation will be held on 1 November 2017 at the Univeristy of California, Berkeley.




public comment

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.




public comment

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.




public comment

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.




public comment

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




public comment

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.




public comment

Public comments received on the possible solutions to the tax challenges of digitalisation

On 13 February 2019, interested parties were invited to provide comments on key issues identified in a public consultation document on possible solutions to the tax challenges arising from the digitalisation of the economy. The OECD is grateful to the commentators for their input and now publishes the public comments received.




public comment

OECD invites public comments on draft report on tax morale

As part of the ongoing work on tax morale, the OECD is seeking public comments on itis forthcoming publication What is driving tax morale? An empirical analysis on social preferences and attitudes towards taxation.




public comment

Public comments received on draft report on tax morale

On 10 April 2019, interested parties were invited to provide comments on its forthcoming publication "What is driving tax morale? An empirical analysis on social preferences and attitudes towards taxation". The OECD is grateful to the commentators for their input and now publishes the public comments received.




public comment

Public comments received on the Secretariat Proposal for a "Unified Approach" under Pillar One

On 9 October 2019, interested parties were invited to provide comments on a number of policy issues and technical aspects in respect to the Secretariat Proposal for a "Unified Approach" under Pillar One. The OECD is grateful to the commentators for their input and now publishes the public comments received.




public comment

Public comments received on the Global Anti-Base Erosion (GloBE) Proposal under Pillar Two

On 8 November 2019, interested parties were invited to provide comments on certain aspects of the Global Anti-Base Erosion (GloBE) Proposal under Pillar Two. The OECD is grateful to the commentators for their input and now publishes the public comments received.




public comment

Public comments received on the 2020 Review of Country-by-Country Reporting (BEPS Action 13 Minimum Standard)

On 6 Feburary 2020, interested parties were invited to provide comments on the Review of the BEPS Action 13 minimum standard. The OECD is grateful to the commentators for their input and now publishes the public comments received.




public comment

Public comments received on the draft Model Rules for Reporting for Platform Operators with respect to Sellers in the Sharing and Gig Economy

On 19 February 2020, interested parties were invited to provide comments on the draft Model Rules for Reporting for Platform Operators with respect to Sellers in the Sharing and Gig Economy. The OECD is grateful to the commentators for their input and now publishes the public comments received