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…
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…
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…
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…
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…
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…
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…
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…
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…
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…