Latest Documents


  • 22-September-2014

    English, PDF, 957kb

    Part 2 of a report to G20 Development Working Group on the impact of BEPS in Low Income Countries

    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.

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  • 21-September-2014

    English, PDF, 618kb

    OECD Secretary-General Report to the G20 Finance Ministers and Central Bank Governors, September 2014, Cairns

    This report consists of two parts. Part I is a report by the OECD Secretary-General regarding (A) the OECD/G20 BEPS Project; (B) the single global common standard on Automatic Exchange of iInformation; and (C) Tax and Development. Part II is a Progress Report to the G20 by the Global Forum on Transparency and Exchange of Information for Tax Purposes.

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  • 16-September-2014

    English

    Webcast 4: Launch of 2014 Deliverables

    Senior members from the OECD's Centre for Tax Policy and Administration (CTPA) gave the latest update on: Overview of the BEPS Project and update on the 2014 deliverables.

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  • 16-September-2014

    English

    Preventing the Granting of Treaty Benefits in Inappropriate Circumstances

    This report includes proposed changes to the OECD Model Tax Convention to prevent treaty abuse. Countries participating in the BEPS Project have agreed on a minimum standard to prevent treaty shopping and other strategies aimed at obtaining inappropriately the benefit of certain provisions of tax treaties. The report also ensures that tax treaties do not inadvertently prevent the application of legitimate domestic anti-abuse rules. The report clarifies that tax treaties are not intended to be used to generate double non-taxation and identifies the tax policy considerations that countries should consider before deciding to enter into a tax treaty with another country. The model provisions included in the report provide intermediary guidance as additional work is needed, in particular in relation to the limitation on benefits rule.

  • 16-September-2014

    English

    Guidance on Transfer Pricing Aspects of Intangibles

    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.

  • 16-September-2014

    English

    Developing a Multilateral Instrument to Modify Bilateral Tax Treaties

    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.

  • 16-September-2014

    English

    Addressing the Tax Challenges of the Digital Economy

    The spread of the digital economy poses challenges for international taxation. This report sets out an analysis of these tax challenges. It notes that because the digital economy is increasingly becoming the economy itself, it would not be feasible to ring-fence the digital economy from the rest of the economy for tax purposes. The report notes, however, that certain business models and key features of the digital economy may exacerbate BEPS risks. These BEPS risks will be addressed by the work on the other Actions in the BEPS Action Plan, which will take the relevant features of the digital economy into account. The report also analyses a number of broader tax challenges raised by the digital economy, and discusses potential options to address them, noting the need for further work during 2015 to evaluate these broader challenges and potential options.

  • 16-September-2014

    English

    Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance

    Preferential regimes continue to be a key pressure area in international taxation. The OECD’s 2013 BEPS report recognises that these need to be dealt with more effectively and the work of the Forum on Harmful Tax Practices (FHTP) needs to be refocused with an emphasis on substance and transparency. This is an interim report that sets out the progress made to date.

  • 16-September-2014

    English

    BEPS 2014 Deliverables

    The OECD Committee on Fiscal Affairs (CFA), bringing together 44 countries on an equal footing (all OECD members, OECD accession countries, and G20 countries), has adopted a first set of seven deliverables described in the Action Plan and due in 2014.

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  • 16-September-2014

    English

    Guidance on Transfer Pricing Documentation and Country-by-Country Reporting

    This document contains revised standards for transfer pricing documentation and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. These new reporting provisions, and the transparency they will encourage, will contribute to the objective of understanding, controlling, and tackling BEPS behaviours. Countries participating in the BEPS project will carefully review the implementation of these new standards and will reassess no later than the end of 2020 whether modifications should be made to require reporting of additional or different data. Effective implementation of the new reporting standards and reporting rules will be essential. Additional work will be undertaken to identify the most appropriate means of filing the required information with and disseminating it to tax administrations.

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