This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles. The changes clarify the definition of intangibles and provide guidance for related parties; including transactions involving intangibles and the transfer pricing treatment of local market features and corporate synergies. Some transfer pricing issues relating to intangibles are closely related to other issues that are to be addressed during 2015, most notably in relation to the allocation of risk among MNE group members and recharacterisation of transactions. Because of those interactions some sections of this document are in intermediate form and will be finalised in 2015.
This report identifies the issues arising from the development of a multilateral instrument that modifies bilateral tax treaties. Without a mechanism for swift implementation, changes to model tax conventions only widen the gap between the content of these models and the content of actual tax treaties. Developing such a mechanism is necessary not only to tackle base erosion and profit shifting, but also to ensure the sustainability of the consensual framework to eliminate double taxation. This is an innovative approach with no exact precedent in the tax world, but precedents for modifying bilateral treaties with a multilateral instrument exist in various other areas of public international law. Drawing on the knowledge of experts in public international law and taxation, the Report concludes that a multilateral instrument is desirable and feasible, and that negotiations for such an instrument should be convened quickly.
Heads of tax crime investigation in 44 countries, as well as the Financial Action Task Force and World Customs Organisation, have come together this week at Europol Headquarters in the Hague for the second meeting of the OECD Forum of Heads of Tax Crime Investigation.
The OECD Model Tax Convention and the worldwide network of tax treaties based upon it help to avoid the danger of double taxation in the case of cross-border investment.
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The rules of procedure concerning the signing of the Multilateral Convention on Mutual Assistance in Tax Matters.
The OECD Model Tax Convention provides the basis for the negotiation and interpretation of more than 3000 tax treaties that make up a network that co-ordinate the income and corporate tax systems of most countries with the objective of removing tax barriers to cross-border trade and investment.
This publication is the ninth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. This shorter version contains the full text of the Model Tax Convention on Income and on Capital as accepted on 15 July 2014, but without the historical notes, the detailed list of conventions between OECD member countries and the background reports that are included in the full-length version, which will appear soon.
Public comments are invited on request for input on BEPS Action 11 regarding work on establishing methodologies to collect and analyse data on BEPS and the actions to address it.
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At the G20’s request, the OECD is leading the development of a strategy to address base erosion and profit shifting (BEPS). The Development Working Group has asked the OECD to draw together the experiences of developing countries and international organisations in a report on the main sources of BEPS in developing countries and how these relate to the OECD/G20 BEPS Action Plan on this issue.
The Standard for Automatic Exchange of Financial Account Information, developed by the OECD with G20 countries, represents the international consensus on automatic exchange of financial account information for tax purposes, on a reciprocal basis. Over 60 jurisdictions have committed to implementing the Standard and all financial centres have been called to match those commitments, as of July 2014.
This publication is the first edition of the full version of the Standard for Automatic Exchange of Financial Account Information. It contains the text of the Model Competent Authority Agreement and the Common Reporting Standard, and the Commentaries thereon, as they read on 15 July 2014. It also includes multilateral and nonreciprocal versions of the Model Competent Authority Agreement, the technical modalities and a wider approach to the Common Reporting Standard.
Co-operation between tax administrations is critical in the fight against tax evasion and protecting the integrity of tax systems. A key aspect of that co-operation is exchange of information.