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 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 May 23 2016, the OECD Council approved the amendments to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“Transfer Pricing Guidelines”), as set out in the BEPS Report on Actions 8-10 “Aligning Transfer Pricing Outcomes with Value Creation” and the 2015 BEPS Report on Action 13…
On May 31, 2016, the OECD published a request for input related to the development of a multilateral instrument to implement the tax-treaty related BEPS measures. The report on Action 15 of the BEPS Action Plan (Developing a Multilateral Instrument to Modify Bilateral Tax Treaties) concludes that a multilateral…
On April 8. 2016, the government officials from around the world called on the OECD to convene a special project meeting of the Joint International Tax Shelter Information and Collaboration (JITSIC) Network to explore possibilities of co-operation and information-sharing, identify tax compliance risks and agree collaborative action, in light…
On February 23, 2016, the OECD agreed on a new framework that would allow all interested countries and jurisdictions to join in efforts to update international tax rules. The new forum will provide an opportunity for all interested countries and jurisdictions to participate as BEPS Associates in an extension…