The OECD announced on 15 June 2016, that on 23 May 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 2015 BEPS Report...
On 16 March 2016, the HM Treasury has published a ‘Business tax road map’ which sets out the government’s plans for business taxes to 2020 and beyond. The road map brings to a conclusion several key areas of tax policy...
It is not a question anymore whether the EU is a strong player at the tax policy field. The question is how strong… In the course of 2016, we expect a series of legislative and non- legislative initiatives to reshape...
Background By way of recap, hybrid mismatch arrangements are arrangements intended to secure tax advantages (mismatches) within multinational groups resulting from differences in tax treatment of the same instrument or entity between different jurisdictions. Hybrid mismatch arrangements can arise both...
The draft Finance Bill 2016 includes provisions to amend the existing patent box regime within Part 8A of CTA 2010, to bring it in line with the ‘nexus’ approach. Construction of the new provisions The majority of the new provisions...
Action 2 of the G20-OECD Base Erosion and Profits Shifting (BEPS) projects concerns hybrid mismatch arrangements. These are arrangements intended to secure tax advantages (mismatches) within multinational groups resulting from differences in tax treatment of the same instrument or entity...
"Is the taxation a poisoned chalice?" That is what many told to Commissionaire Pierre Moscovici when he found out that President Juncker had given him the taxation portfolio. In the last eighteen months, the European Commission’s and OECD’s strong commitment...
On 5 October, the OECD has issued the Final Reports on the BEPS 15 Action points and it is expected that the G20 Finance Ministers will discuss and endorse the Reports and the recommended changes at their meeting on 8...
The Organisation for Economic Co-operation and Development (‘OECD’) held its final public consultation on Actions 8-10 (transfer pricing/'TP') of the Base Erosion and Profit Shifting (BEPS) project on 6 and 7 July 2015. The first day of meeting focused on...
On 9 July 2015, the OECD released a discussion draft on options for low income countries' effective and efficient use of tax incentives for investment. This Discussion Draft is a result of the G20’s Development Working Group (DWG) who has...
The European Commission presented an Action Plan to fundamentally reform corporate taxation in the EU on 17 June 2015. The Action Plan sets out a series of initiatives to tackle tax avoidance, secure sustainable revenues and strengthen the Single Market...
The OECD reached a new milestone when the work on the development of the Multilateral Instrument to implement the tax treaty-related BEPS Action Plan began on 27 May 2015 in Paris. As per the OECD/G20 mandate, the ad hoc Group...
The OECD published its revised discussion draft on Action 6 (Prevent the granting of treaty benefits in inappropriate circumstances) of the Action Plan on Base Erosion and Profit Shifting (BEPS) on 22 May 2015. Public comments are invited on the revised discussion...
Commissioner Moscovici highlighted the re-launch of a debate on the Common Consolidated Corporate Tax Base (CCCTB) on 29 April as a part of the EU Commission’s Action Plan. This Action Plan will build on 5 key actions, starting with the relaunch...
The OECD invited public comments on a Discussion Draft which deals with work in relation to Action 8 of the Action Plan on Base Erosion and Profit Shifting (BEPS) on 29 April. Action 8 covers the transfer pricing of intangibles...
On 16 April 2015, the OECD has invited public comments on a discussion draft which deals with Action 11 - Improving the analysis of BEPS. Action 11 of the BEPS Action Plan focuses on improving the availability and analysis of data on...
The OECD has released a Discussion Draft on Action 12 (Mandatory Disclosure Rules) of the BEPS Action Plan on 31 March. The Action Plan calls for this work to be completed by September 2015 and the CFA invites interested parties to...
On 9-10 February 2015, the OECD presented the latest developments in the OECD/G20 project to combat BEPS by multinational enterprises during a G20 Finance Ministers and Central Bank Governors’ meeting in Istanbul, Turkey. In their Communiqué, the G20 Ministers and...
On 21 January, the OECD held a public discussion meeting on BEPS Action 7 focusing on preventing the artificial avoidance of permanent establishment (PE). Action 7 is one of the most discussed action points of the BEPS Action Plan and...
The OECD public consultation meeting on the follow-up work on BEPS Action 6 was held on 22 January 2015 in Paris. Background Action 6 focuses on Prevent the granting of treaty benefits in inappropriate circumstances and paragraph 5 of the Report...
Summary Article 29a of the General Tax Code on the Advance Tax Rulings and Advance Ruling Committee entered into force on 1 January 2015 in Luxembourg; Luxembourg endorsed the EU Commission’s plan to present a draft directive on mandatory automatic...
I am wondering whether it is only me who is facing hundreds of pages of discussion documents inviting stakeholders’ input or are you also sharing the same experience while you are drinking your strong cup of coffee today! It is...
Release of discussion draft on revisions to Chapter I of the Transfer Pricing Guidelines (Including risk, recharacterisation and special measures) The OECD has invited stakeholders' input on the discussion draft which deals with work in relation to Actions 8, 9,...
On 18 December, the OECD has invited public comments on a discussion draft which deals with action 4 (Interest deductions and other financial payments) of the BEPS Action Plan. The use of interest (and in particular related party interest) is...
On 16 December, the OECD published two discussion drafts on Action 10 and has invited public comments on the transfer pricing aspects of cross-border commodity transactions and on the use of profit splits in the context of global value chains...
Following the publication by the International Consortium of Investigative Journalists (“ICIJ consortium”) of over 300 advance tax rulings issued by the Luxembourg tax administration between 2002 and 2010, the Luxembourg Ministry of Finance organised a press conference and issued a press...
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...
The OECD released its new Strategy for Deepening Developing Country Engagement in the Base Erosion and Profit Shifting (BEPS) Project on 12 November 2014, which will strengthen their involvement in the decision-making processes and bring them to the heart of...
On 3 November, OECD released a discussion draft of proposed modifications to Chapter VII of the Transfer Pricing Guidelines relating to low value-adding intra-group services for comment by interested parties. This document is also available in French and Spanish. The...
OECD/BEPS: Release of discussion draft on Action 7 (Prevent the Artificial Avoidance of PE Status) of the BEPS Action Plan On 31 October 2014, OECD has invited invited public comments on a discussion draft which includes the preliminary results of...
Today, the OECD published the comments received on the discussion draft on the paper on Transfer Pricing Comparability Data and Developing Countries. The comments were received in response to the invitation launched by the OECD on 11 March 2014. Background...
On 23 and 24 October, Heads of Tax Administration from 38 countries met in Dublin, Ireland for the 9th meeting of the Forum on Tax Administration (FTA). The FTA is the leading international body concerned with tax administration, bringing together...
Today, Mazars was very pleased to welcome Dr Tom O’Shea and his LL.M in International Tax Law students from the Centre for Commercial Law Studies, Queen Mary, University of London. Dr Tom O’Shea delivered a very interesting guest lecture entitled...
On 7 October 2014, the OECD published comments received following a request for input on Action 11 (Establish methodologies to collect and analyse data on BEPS and the actions to address it) of the Action Plan on Base Erosion and...
United Nations Subcommittee on Base Erosion and Profit Shifting (BEPS) had invited the developing countries to provide feedback by answering the UN Questionnaire including 10 questions. This summary focuses on the responses provided by China and India. In its response, India...
11 days after the warm welcome and endorsement of the 7 Deliverables (2014) by the G20 in Cairns, the OECD published a revised calendar for stakeholders' input. The announcement emphasized that the timeline of the OECD/G20 Base Erosion and Profit...
We welcome the OECD's continued work on the impact of BEPS in low income countries. The OECD published Part II of a two-part report to the G20 Development Working Group (DWG) on the impact of BEPS in low income countries....
This September is a very challenging and landmark period for the international tax world. The OECD releases its first recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises under the OECD/G20 Base Erosion and Profit Shifting (BEPS)...
The OECD will release its first recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project on Tuesday 16 September 2014. The OECD Secretary General Angel Gurría...
On 1 September 2014, the Organization for Economic Co-operation and Development (the OECD) published the condensed version of the OECD Income and Capital Model Convention and Commentary 2014 (2014 Update). This is the ninth edition of the condensed version of...
This September will be a very exciting period for the international tax world and it is expected that the BEPS project marks its first turning point in the history of international co-operation on taxation. Pascal Saint-Amans, Director of OECD Centre...
On 5-6 September 2013, the G20 leaders endorsed the OECD Action Plan to tackle base erosion and profit shifting (BEPS) in St Petersburg. The Development Working Group (DWG) asked the OECD to draw together the experiences of developing countries and...
On 2 April 2014 the OECD presented a second update on the BEPS (Base Erosion and Profit Shifting) project via a webcast, which is available for viewing on the OECD website (link). The key message was that the BEPS project...
The OECD has published a revised timetable for the various elements of its Action Plan in its BEPS project. The timescales involved in this project are extremely tight, so it is not surprising to see that the plans in some...
On 13th February 2014, the OECD presented their latest weapon in the attack of global tax avoidance. The new standard builds on specific country agreements and 2010 US FATCA provisions to drive greater transparency and disclosure. In essence the standard...
Base erosion and profit shifting (BEPS) refers to the situation where there is a divorce between the location of profit and the location of the value creation. The OECD issued a detailed Action Plan to tackle BEPS. On 23 January...
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