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Closing tax gaps - OECD launches Action Plan on Base Erosion and Profit Shifting

National tax laws have not kept pace with the globalisation of corporations and the digital economy, leaving gaps that can be exploited by multi-national corporations to artificially reduce their taxes.




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Release of discussion draft on Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan

Public comments are invited on a discussion draft that includes the proposals produced with respect to Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan.




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Release of discussion drafts on Action 2 (Neutralise the effects of hybrid mismatch arrangements) of the BEPS Action Plan

Public comments are invited on discussion drafts that include the proposals produced with respect to Action 2 (Hybrid Mismatch Arrangements) of the BEPS Action Plan.




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Release of discussion draft on Action 1 (Tax Challenges of the Digital Economy) of the BEPS Action Plan

Public comments are invited on a discussion draft that includes the proposals produced with respect to Action 1 (Tax Challenges of the Digital Economy) of the BEPS Action Plan.




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Public comments received on discussion draft on Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan

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




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Advancing global action to support fiscal sustainability

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




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OECD releases public request for input on BEPS Action 11

Public comments are invited on request for input on BEPS Action 11 regarding work on establishing methodologies to collect and analyse data on BEPS and the actions to address it.




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Comments published on BEPS Action 11 request for input

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.




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Heads of Tax Administration agree global actions to meet global challenges

The Ninth Meeting of the OECD Forum on Tax Administration (FTA) met in Dublin, Ireland on 23-24 October to discuss the implementation of the BEPS Project and automatic exchange of information.




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

The Committee on Fiscal Affairs (CFA) invites interested parties to send comments on this discussion draft, which includes the preliminary results of the work carried on with respect to issues related to the artificial avoidance of PE status and includes proposals for changes to the definition of permanent establishment found in the OECD Model Tax Convention.




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Release of a discussion draft on follow-up work on Action 6 (Prevent treaty abuse) of the BEPS Action Plan

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.




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Release of discussion draft on the use of profit splits in the context of global value chains as part of the work on BEPS Action 10

Public comments are invited on the discussion draft on the use of profit splits in the context of global value chains, released as part of the work in relation to Action 10 of the BEPS Action Plan.




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Release of discussion draft on the transfer pricing aspects of cross-border commodity transactions

Public comments are invited on the discussion draft on the Transfer Pricing aspects of cross-border Commodity transactions released as part of the OECD Centre for Tax Policy's work on Action 10 of the Action Plan on Base Erosion and Profit Shifting.




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Release of a discussion draft on Action 4 (Interest deductions and other financial payments)

Public comments are invited on a discussion draft which deals with action 4 (Interest deductions and other financial payments) of the BEPS Action Plan




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Release of a discussion draft on Action 14 (Make dispute resolution mechanisms more effective) of the BEPS Action Plan

Public comments are invited on a discussion draft which deals with the work on Action 14 (“Make dispute resolution mechanisms more effective”) of the BEPS Action Plan.




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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.




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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.




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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.




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Comments received on the discussion draft of proposed modifications to Chapter VII of the Transfer Pricing Guidelines relating to low value-adding intra-group services (BEPS Action 10)

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.




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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.




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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.




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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.




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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.




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Release of a discussion draft on BEPS Action 12 (Mandatory Disclosure Rules)

Public comments are invited on a discussion draft which deals with action 12 (Mandatory Disclosure Rules) of the BEPS Action Plan.




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Release of a discussion draft on BEPS Action 11 (Data Analysis)

Public Comments are invited on a discussion draft which deals with Action 11 (Improving the analysis of BEPS) of the BEPS Action Plan.




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Release of a discussion draft on BEPS Action 8 (Cost contribution arrangements)

Public comments are invited on this discussion draft which deals with work in relation to Action 8 of the BEPS Action Plan.




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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.




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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.




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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.




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Release of a new discussion draft on BEPS Action 7 (Prevent the Artificial Avoidance of PE Status)

Public comments are invited on a new discussion draft which includes proposals resulting from the work on Action 7 (Prevent the Artificial Avoidance of PE Status) of the Action Plan on Base Erosion and Profit Shifting (BEPS).




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Release of a revised discussion draft on BEPS Action 6 (Prevent Treaty Abuse)

Public comments are invited on a new discussion draft which includes proposals on how to deal with the follow-up work on Action 6 (Prevent Treaty Abuse) of the Action Plan on Base Erosion and Profit Shifting (BEPS).




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Release of a discussion draft on BEPS Action 8 (Hard-to-value intangibles)

Public comments are invited on a discussion draft which deals with work in relation to Action 8 of the Action Plan on Base Erosion and Profit Shifting




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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.




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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.




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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.




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OECD agrees on course of action in response to EU request to include additional fields in the CRS XML Schema

On 1 December 2015 the OECD agreed on a common way forward in response to a request submitted by the European Commission pursuant to a mandate from EU Member States to include additional fields in the CRS XML Schema. This request was made further to the work of the European Commission and the EU Member States on the implementation of the Standard for Automatic Exchange of Financial Information in Tax Matters within the European Union.




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Concrete actions needed to advance global tax transparency, OECD says

The international community should call time on all remaining holdouts who have yet to implement internationally agreed tax transparency standards, OECD Secretary General Angel Gurría said in a new report to the G20.




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OECD appoints new Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division in the Centre for Tax Policy and Administration

Mr Jefferson VanderWolk has been appointed Head of the Tax Treaty, Transfer Pricing & Financial Transactions Division in the Centre for Tax Policy and Administration. He will take up his duties in early July 2016.




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OECD releases discussion draft on branch mismatch structures under Action 2 of the BEPS Action Plan

Interested parties are invited to provide comments on a discussion draft which deals with branch mismatch structures under Action 2 (Neutralising the Effects of Hybrid Mismatch Arrangements) of the BEPS Action Plan.




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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.




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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.




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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.




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Carbon pricing efforts are falling short, but even modest collective action can deliver significant progress, OECD says

Current carbon prices are falling short of the levels needed to reduce greenhouse gas emissions driving climate change, but even moderate price increases could have a significant impact, according to new OECD research.




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OECD releases schedule for Action 14 peer reviews and invites taxpayer input

On 20 October, the OECD released the key documents that will form the basis of the Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan. In accordance with the Assessment Methodology, the reviews will be conducted in batches, with the first batch commencing in December 2016.




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OECD releases additional guidance on Action 4 of the BEPS Action Plan to curb international tax avoidance

Today, the OECD released an updated version of the BEPS Action 4 Report (Limiting Base Erosion Involving Interest Deductions and Other Financial Payments), which includes further guidance on two areas: the design and operation of the group ratio rule, and approaches to deal with risks posed by the banking and insurance sectors.




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Interaction between the tax treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds

Comments are invited on draft examples included in a discussion draft on the follow-up work on the ineraction between the treaty provisions of the report on BEPS Action 6 and the treaty entitlement of non-CIV funds.




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Seven more jurisdictions sign 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), Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the Russian Federation have now signed the Multilateral Competent Authority Agreement for Country-by-Country Reporting (CbC MCAA), bringing the total number of signatories to 57. Lithuania and Hungary joined the Agreement in October and December 2016 respectively.




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

The OECD is now gathering input for the Stage 1 peer reviews of Austria, France, Germany, Italy, Liechtenstein, Luxembourg and Sweden, 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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OECD releases peer review documents for assessment of BEPS minimum standards (Actions 5 and 13)

Today the OECD released key documents, approved by the Inclusive Framework on BEPS, which will form the basis of the peer review of Action 13 Country-by-Country Reporting and for the peer review of the Action 5 transparency framework.




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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.