OECD updates Multi-Country Analysis of Existing Transfer Pricing Simplification Measures

The OECD has updated Article 26 of the OECD Model Tax Convention, which sets out the international standard on exchange of information. The standard provides for information exchange on request, where the information is “foreseeably relevant” for the administration of the taxes of the requesting party, regardless of bank secrecy and a domestic tax interest.

All of the world’s financial centres, under the impetus of the G20, and adopting the standards developed by the OECD, made a commitment in 2009 to putting an end to tax-motivated bank secrecy. Most of the countries have kept their word but major progress must still be made, said OECD Secretary-General.

OECD governments have committed to stepping up their efforts to tackle base erosion and profit shifting (BEPS) by endorsing the OECD's BEPS Declaration at the Organisation’s annual Ministerial Meeting in Paris.

The OECD today presented to G20 finance ministers plans for a two-pronged attack on tax avoidance and evasion from both companies and individuals.

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 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.

Article about OECD work with international partners to eradicate tax evasion and tax avoidance, published in G7 Brussels Summit magazine, June 2014

The OECD Council approved yesterday the contents of the 2014 update to the OECD Model Tax Convention. The update will be incorporated in a revised version of the Model Tax Convention that will be published in the next few months.

At the G20’s request, the OECD is leading the development of a strategy to address base erosion and profit shifting (BEPS). The Development Working Group has asked the OECD to draw together the experiences of developing countries and international organisations in a report on the main sources of BEPS in developing countries and how these relate to the OECD/G20 BEPS Action Plan on this issue.

Action 10 of the Action Plan on Base Erosion and Profit Shifting directs the OECD to develop transfer pricing rules to provide protection against common types of base eroding payments. A discussion draft of proposed modifications to Chapter VII of the Transfer Pricing Guidelines relating to low value-adding intra-group services was released for comment by interested parties today

Public comments are invited on a discussion draft which deals with follow-up work mandated by the Report on Action 6 (“Prevent the granting of treaty benefits in inappropriate circumstances”) 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.

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 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.

SMEs form the vast majority of businesses in most countries and contribute strongly to employment and economic growth, but they face particular challenges, particularly as concerns access to finance. Governments have a range of policy levers, including tax policies, that can and should be used to support the growth and development of SMEs, according to a new OECD report.

The CREDAF Working group on BEPS held its second physical meeting in Paris on 2 November 2015, following the one that took place in Kinshasa on 27 May 2015. Twenty five participants gathered to discuss the work to be performed within the implementation phase of the OECD/G20 BEPS Project.

While the digital economy cannot be separated out from the rest of the economy, it is equally clear that some specific features of the digital economy may exacerbate the risks of base erosion and profit shifting for tax purposes–namely mobility (e.g. intangibles, business functions), reliance on data (and other forms of user input), network effects, and the spread of multi-sided business models.

G20 Finance Ministers, in their communique of February 2016, called upon the IMF, OECD, UN and World Bank Group to “recommend mechanisms to help ensure effective implementation of technical assistance programmes, and recommend how countries can contribute funding for tax projects and direct technical assistance, and report back with recommendations” at their July meeting.

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

The OECD received a strong endorsement from both the G20 Leaders and Finance Ministers to work on solutions to support certainty in the tax system with the aim to promote investment, trade and balanced growth. As part of a wider project, the OECD launches a Business Survey to invite businesses and other stakeholders to contribute their views on tax certainty.

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.

The Inclusive Framework on BEPS has released additional guidance to provide essential information that will give certainty to tax administrations and MNE Groups alike on implementation of Country-by-Country (CbC) reporting (BEPS Action 13).

A portfolio of relevant side events will complement the official programme of the 2017 ECOSOC Forum on Financing for Development follow-up (22-25 May 2017) and provide additional space for all stakeholders and participants to discuss substantive matters in greater detail.

The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which represents the international consensus on the valuation, for income tax purposes, of cross-border transactions between associated enterprises.

The OECD has just released the draft contents of the 2017 update to the OECD Model Tax Convention. Comments are requested at this time only with respect to certain parts of the 2017 update that have not previously been released for comments.

The Inclusive Framework on BEPS has released additional guidance to give certainty to tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) Reporting (BEPS Action 13).

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

Today, the OECD has released updated and new IT-tools and guidance to support the technical implementation of the exchange of tax information under the Common Reporting Standard (CRS), on Country-by-Country Reporting (CbC) and in relation to tax rulings (ETR).

The OECD has published updated versions of transfer pricing country profiles (TPCP), reflecting the current transfer pricing legislation and practices of a large number of participating countries.

On 21 November 2017 the OECD Council approved the contents of the 2017 update to the OECD Model Tax Convention. The update will be incorporated in a revised version of the Model Tax Convention that will be published in the next few months.

On 28 November 2017, an OECD delegation met Bakhyt Sultanov, the Kazakhstan Minister of Finance, in Astana to launch an initiative to assist Kazakhstan in the implementation of the measures to tackle Base Erosion and Profit Shifting (BEPS).

The Inclusive Framework on BEPS has released additional guidance to give certainty to tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) Reporting (BEPS Action 13).

The latest edition of the OECD Model Tax Convention, an international instrument which serves as a model for countries concluding bilateral tax conventions, has been released today, incorporating significant changes developed under the OECD/G20 project to address base erosion and profit (BEPS).

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.

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.

Today, in Ouagadougou, an OECD delegation met the Minister of Economy, Finance and Development of Burkina Faso, Mrs. Hadizatou Rosine Coulibaly, to discuss the progress made in the implementation of new international tax standards.

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

On 4 July 2018, in Abidjan, an OECD delegation met with the State Secretariat to the Prime Minister in charge of Budget and State Portfolio to discuss the progress made in the implementation of new international standards to combat tax fraud and tax evasion.

As part of a mission held from 16 to 19 July 2018 in Islamabad, Pakistan aimed at launching the induction programme to support the implemention of the BEPS measures and initiating the TIWB programme, an OECD delegation met in Islamabad to discuss the progress of the country in implementing the new international standards to combat tax avoidance and tax evasion.

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.

The Inclusive Framework on BEPS has released additional interpretative guidance to give certainty to tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) Reporting (BEPS Action 13).

Since the release of the guidance, Monaco has provided additional information with respect to its residence and migration requirements confirming that information on relevant applicants is exchanged with all existing jurisdictions of residence.

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.

As part of its efforts to maintain the integrity of the Common Reporting Standard (CRS), the OECD has been working closely with Panama over the last weeks to ensure that any risks created by its Residence by Investment (RBI) programmes are effectively addressed.

This week, in the margins of the 11th Global Forum meeting held in Punta del Este, Uruguay Minister of Economy and Finance Danilo Astori led a discussion with Ministers, high level representatives and officials from Latin America on the use of information exchange to combat tax fraud and corruption.

Distance-based charges can help sustain tax revenues and improve environmental and mobility outcomes as future vehicles rely less on fossil fuels. According to a new report, tax revenue from diesel and gasoline use in private cars is likely to decline substantially in the coming decades. This would put stress on government budgets, particularly in countries where fuel tax revenues represent a large share of total revenue.

The OECD is encouraging tax administrations around the globe to step up their efforts to support the fight against money laundering and terrorist financing with the launch of a handbook intended to raise the awareness of tax examiners, auditors, and investigators of the important role they can play in combatting these crimes.

In order to support the automatic exchange of information collected under the OECD’s Model Mandatory Disclosure Rules on Common Reporting Standard (CRS) Avoidance Arrangements and Opaque Offshore Structures (MDRs), the OECD has today released the international administrative and operational framework for the exchange of information collected under the MDRs.

At their Summit in Osaka this weekend, G20 leaders agreed on a range of priorities for which analysis and support from the OECD and other international organisations are playing a crucial role.