OECD releases additional guidance on implementation of the Country-by-Country (CbC) reporting (BEPS Action 13)

  • By A&S
  • April 7, 2017
  • News

On April 6, 2017, the Inclusive Framework on BEPS released additional guidance to provide essential information on implementation of the Country-by-Country (CbC) reporting (BEPS Action 13). The updated CbC guidance document contains additional information clarifying several interpretation issues related to the data to be included in the CbC report…

read more

OECD BEPS Multilateral Instrument text published – first signing ceremony scheduled for June 2017

  • By A&S
  • November 25, 2016
  • News

On November 24, 2016, the OECD published a press release that more than 100 jurisdictions have concluded negotiations on a multilateral instrument (MLI) that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises. The…

read more

European Commission proposes major corporate tax reform

  • By A&S
  • October 26, 2016
  • News

On October 25, 2016, the European Commission (EC) published plans to overhaul the way in which companies are taxed within the EU, with the aim of delivering a growth-friendly and fair corporate tax system. There are three separate initiatives and related directive proposals included in the package: I. The Common Consolidated…

read more

OECD releases a discussion draft on branch mismatch structures (BEPS Action 2)

  • By A&S
  • August 22, 2016
  • News

On August 22, 2016, the OECD released a discussion draft on branch mismatch structures. The report on BEPS Action 2 (Neutralising the Effects of Hybrids Mismatch Arrangements) sets out recommendations for domestic rules designed to neutralize mismatches in tax outcomes that arise in respect of payments under a hybrid…

read more

OECD releases a discussion draft on interest in the banking and insurance sectors (BEPS Action 4)

  • By A&S
  • July 28, 2016
  • News

On July 28, 2016, the OECD released a discussion draft on approaches to address base erosion and profit shifting involving interest in the banking and insurance sectors. The final version of the report on Action 4 (Limiting Base Erosion Involving Interest Deductions and Other Financial Payments) set out a…

read more

OECD releases a discussion draft on the Group Ratio Rule (OECD BEPS Action 4)

  • By A&S
  • July 12, 2016
  • News

On July 11, 2016, the OECD released a discussion draft on elements of the design and operation of the Group Ratio Rule with respect of interest deduction limitations. The final version of the report on Action 4 (Limiting Base Erosion Involving Interest Deductions and Other Financial Payments) includes a…

read more

OECD releases a discussion draft on the attribution of profits to permanent establishments (OECD BEPS Action 7)

  • By A&S
  • July 5, 2016
  • News

On July 4, 2016, OECD released a discussion draft concerning additional guidance on the attribution of profits to permanent establishments. The Final Report on Action 7 of the BEPS Action Plan (“Preventing the Artificial Avoidance of Permanent Establishment Status”) mandates follow-up work to develop additional guidance on the issue of attribution…

read more

OECD releases discussion draft on revised guidance for application of profit split method (BEPS Actions 8-10)

  • By A&S
  • July 5, 2016
  • News

On July 4, 2016, OECD released a discussion draft concerning the revised guidance for profit split method. The Final Report on Actions 8-10 of the BEPS Action Plan (“Assure that transfer pricing outcomes are in line with value creation”) sets out the scope of the work in relation to…

read more

OECD publishes additional guidance on Country-by-Country Reporting (BEPS Action 13)

  • By A&S
  • June 30, 2016
  • News

On June 29, 2016, the OECD published a memorandum titled Guidance on the Implementation of Country-by-Country (CbC) Reporting. As described in the original press release, the OECD/G20 BEPS Project set out 15 key actions to reform the international tax framework and ensure that profits are reported where economic activities…

read more

Member States agree on Anti Tax Avoidance Package

  • By A&S
  • June 21, 2016
  • News

On June 21, 2016, the Member States of the European Union agreed on their general approach for far-reaching new rules to eliminate the most common corporate tax avoidance practices, also known as the Anti Tax Avoidance Package. First proposed by the European Commission in January 2016, the measures in…

read more