Public comments received on the discussion draft on the meaning of “beneficial owner” in the OECD Model Tax Convention

On 31 May 2011, the OECD Committee on Fiscal Affairs released for public comment a discussion draft on the application of the provisions of the OECD Model Tax Convention to the cross-border trading of emissions permits. The OECD has now published the comments received on this consultation draft.

Public comments received on the proposed changes to the Commentary on Article 5 (Permanent Establishment) of the OECD Model Tax Convention.

OECD invites comments on certain transfer pricing timing issues

On 6 June 2012, the OECD released an invitation to comment on a discussion draft on the Transfer Pricing Aspects of Intangibles. The comments received in response to this invitation have been published. This edition replaces the previous edition released on 28 September 2012.

On 6 June 2012, the OECD released an invitation to comment on a discussion draft on the revision of the Safe Harbours Section in Chapter IV of the Transfer Pricing Guidelines. The comments received in response to this invitation have been published. This edition replaces the previous edition released on 28 September 2012.

On 6 June 2012, the OECD released an invitation to comment on a discussion draft on timing issues relating to transfer pricing. The comments received in response to this invitation have been published. This edition replaces the previous edition released on 28 September 2012.

On 19 October 2012, the OECD Committee on Fiscal Affairs released for public comment revised proposals concerning the meaning of “beneficial owner” in Articles 10, 11 and 12 of the OECD Model Tax Convention. The OECD has now published the comments received on this revised discussion draft.

On 19 October 2012, the OECD Committee on Fiscal Affairs released for public comment a revised discussion draft on tax treaty issues related to emissions permits and credits. The OECD has now published the comments received on this revised discussion draft.

On 19 October 2012, the OECD Committee on Fiscal Affairs released for public comment a revised discussion draft on the definition of “permanent establishment” (Article 5) of the OECD Model Tax Convention. The OECD has now published the comments received on this revised discussion draft.

As part of its project on transfer pricing simplification, the OECD has released a White Paper on Transfer Pricing Documentation. Comments of interested persons are requested by 1 October 2013.

The OECD released for public comment a Revised Discussion Draft on Transfer Pricing Aspects of Intangibles. The Revised Discussion Draft updates and expands an earlier discussion draft released in June 2012 to reflect comments received and further discussions of country delegates to Working Party No. 6 of the Committee on Fiscal Affairs. Comments of interested persons are requested by 1 October 2013.

Following the recent invitations for public comment on four new draft elements of the OECD International VAT/GST Guidelines, the OECD has now published the comments received which will be used to inform the OECD’s work in this area.

On 30 April 2013, the OECD invited comments from interested parties on the new Draft Handbook on Transfer Pricing Risk Assessment, produced by the Steering Committee of the OECD Global Forum on Transfer Pricing. The OECD now publishes the comments received.

On 30 July 2013, the OECD invited comments from interested parties on the White paper on Transfer Pricing Documentation, released as part of its project on transfer pricing simplification. The OECD now publishes the comments received.

On 30 July 2013, the OECD invited comments from interested parties on the Revised Discussion Draft on Transfer Pricing Aspects of Intangibles. The comments received in response to this invitation have been published.

The OECD invites public comments on a discussion draft that includes proposed changes to the OECD Model Tax Convention dealing with the operation of ships and aircraft in international traffic.

The OECD Committee on Fiscal Affairs invites public comments on a discussion draft that includes various technical changes to be included in the next update to the OECD Model Tax Convention.

On 25 June 2013, the OECD released for public comment a discussion draft on the tax treatment of various payments that may be made following the termination of an employment. The OECD has now published the comments received on this discussion draft.

On 22 November 2013, a request for public comments on the tax challenges of the digital economy was launched. The OECD now publishes the comments received.

On 22 October 2013, the OECD requested interested parties to send a short description of strategies that might be considered to result in the artificial avoidance of PE status in relation to base erosion and profit shifting. The OECD has now published the only response received following that invitation.

On 15 November 2013, the OECD Committee on Fiscal Affairs (CFA) invited public comments on a discussion draft on technical changes to be included in the next update to the OECD Model Tax Convention. The OECD has now published the comments received on that discussion draft.

On 15 November 2013, the OECD Committee on Fiscal Affairs (CFA) invited public comments on a discussion draft on changes to the provisions of the OECD Model Tax Convention dealing with the operation of ships and aircraft in international traffic. The OECD has now published the comments received on that discussion draft.

On 30 January 2014, the OECD invited comments from interested parties on the Discussion Draft on transfer pricing documentation and country-by-country reporting. The OECD now publishes the comments received.

The OECD publishes comments received from interested parties on the discussion draft on Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan.

On 24 March 2014, the OECD invited comments from interested parties on the Discussion Draft on Tax Challenges of the Digital Economy related to Action 1 of the BEPS Action Plan. The OECD now publishes the comments received.

OECD publishes comments received on Action 2 discussions drafts (Neutralise the Effects of Hybrid Mismatch Arrangements)

On 4 August 2014, interested parties were invited to comment on BEPS Action 11 regarding work on establishing methodologies to collect and analyse data on BEPS and the actions to address it. Comments received have now been published.

This page shows a full table of comments received from the public on the Interim Draft Paper on Transfer Pricing Comparability Data and Developing Countries.

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.

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.

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.

On 3 November 2014, the OECD invited comments from interested parties on the discussion draft of proposed modifications to Chapter VII of the Transfer Pricing Guidelines covering low value-adding intra-group services relating to Action 10 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.

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.

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.

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.

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)

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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