Latest Documents


  • 30-October-2015

    English

    Model Tax Convention on Income and on Capital 2014 (Full Version)

    This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 15 July 2014, including the Articles, Commentaries, non-member economies positions, the Recommendation of the OECD Council, the historical notes (now expanded to go back to 1963), the detailed list of conventions between OECD member countries and the background reports.

  • 23-October-2015

    English

    OECD holds second regional Network Meeting on BEPS in Eastern Europe and Central Asia

    On 21-23 October 2015, the Eastern Europe and Central Asia Regional Meeting and Governmental Workshop on BEPS discussed the outcomes of the BEPS project, and how countries can engage in the implementation and monitoring of the measures adopted on an equal footing.

    Related Documents
  • 9-October-2015

    English, PDF, 299kb

    OECD Secretary-General's tax report to G20 Finance Ministers (October 2015)

    Report by the OECD Secretary-General regarding the final package of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project. Version française: http://bit.ly/1PnzwnU

  • 9-October-2015

    English

  • 9-October-2015

    English

  • 5-October-2015

    English

    Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance, Action 5 - 2015 Final Report

    Preferential regimes continue to be a key pressure area. Current concerns are primarily about preferential regimes which can be used for artificial profit shifting and about a lack of transparency in connection with certain rulings. The report sets out an agreed methodology to assess whether there is substantial activity. In the context of IP regimes such as patent boxes, agreement was reached on the “nexus approach” which uses expenditures as a proxy for substantial activity and ensures that taxpayers can only benefit from IP regimes where they engaged in research and development and incurred actual expenditures on such activities. The same principle can also be applied to other preferential regimes so that such regimes are found to require substantial activity where the taxpayer undertook the core income generating activities.  In the area of transparency, a framework has been agreed for the compulsory spontaneous exchange of information on rulings that could give rise to BEPS concerns in the absence of such exchange. The results of the application of the existing factors applied by the FHTP, and the elaborated substantial activity and transparency factors, to a number of preferential regimes are included in this report.

  • 5-October-2015

    English

    Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2015 Final Report

    The mobility and fungibility of money makes it possible for multinational groups to achieve favourable tax results by adjusting the amount of debt in a group entity. The recommended approach ensures that an entity’s net interest deductions are directly linked to its level of economic activity, based on taxable earnings before deducting net interest expense, depreciation and amortisation (EBITDA). This approach includes three parts: a fixed ratio rule based on a benchmark net interest/EBITDA ratio; a group ratio rule which allows an entity to deduct more interest expense in certain circumstances based on the position of its worldwide group; and targeted rules to address specific risks. A country may choose not to introduce the group ratio rule, but in this case it should apply the fixed ratio rule to multinational and domestic groups without improper discrimination.

  • 5-October-2015

    English

    Measuring and Monitoring BEPS, Action 11 - 2015 Final Report

    There are hundreds of empirical studies finding evidence of tax-motivated profit shifting, using different data sources and estimation strategies. While measuring the scope of BEPS is challenging given its complexity and existing data limitations, a number of recent studies suggest that BEPS is responsible for significant global corporate income tax (CIT) revenue losses. This report assesses currently available data and concludes that significant limitations severely constrain economic analyses of the scale and economic impact of BEPS and improved data and methodologies are required. Noting these data limitations, a dashboard of six BEPS indicators has been constructed, using different data sources and assessing different BEPS channels. These indicators provide evidence that BEPS exists and has been increasing over time. New empirical analysis estimates that the scale of global CIT revenue losses could be between USD 100 and 240 billion annually at 2014 levels. The report also presents a toolkit to assist countries evaluate the fiscal effects of BEPS countermeasures. The research also finds significant non-fiscal economic distortions arising from BEPS.  The report concludes by making recommendations regarding data and monitoring tools to improve the analysis of BEPS in the future.

  • 5-October-2015

    English

    Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report

    This report includes changes to the OECD Model Tax Convention to prevent treaty abuse. It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement.  It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not inadvertently prevent the application of domestic anti-abuse rules. The report finally includes changes to the OECD Model Tax Convention that clarify that tax treaties are not intended to create opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping) and that identify the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country.

  • 5-October-2015

    English

    Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report

    This report sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements.  Once translated into domestic law, the recommendations in Part 1 of the report will neutralise the effect of cross-border hybrid mismatch arrangements that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part I of the report sets out recommendations for rules to address hybrid mismatches in respect of payments made under a hybrid financial instrument or payments made to or by a hybrid entity.  It also recommends rules to address indirect mismatches that arise when the effects of a hybrid mismatch arrangement are imported into a third jurisdiction. The recommendations are supported by a commentary and examples to illustrate how they should apply. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases.  Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.

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