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Offshore Voluntary Disclosure: Comparative Analysis, Guidance and Policy Advice, September 2010
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This report examines how, in the light of the increase in cross-border activities and investments of business entities and individuals, international co-ordination and collaboration could be advanced through the use of joint audits.
Turkey hosted the sixth meeting of the OECD’s Forum on Tax Administration in Istanbul, on 15-16 September 2010, bringing together more than 130 delegates from 43 countries. Tax Commissioners from OECD and non-OECD countries met to discuss a range of issues associated with administering tax systems in the current economic climate. The meeting, chaired by Douglas H. Shulman, Commissioner IRS USA and FTA Chair, focused in particular on
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This report provides a framework for a voluntary code of conduct for revenue bodies and banks. This is based upon the concepts developed, and proposals set out in the report Building Transparent Tax Compliance by Banks (2009) and the earlier report Study into the Role of Tax Intermediaries (2008).
The financial and economic crisis had a devastating impact on bank profits, with loss-making banks reporting global commercial losses of around USD 400 billion in 2008. This comprehensive report sets the market context for bank losses and provides an overview of the tax treatment of such losses in 17 OECD countries; describes the tax risks that arise in relation to bank losses from the perspective of both banks and revenue bodies; outlines the incentives that give rise to those risks; and describes the tools revenue bodies have to manage these potential compliance risks. It concludes with recommendations for revenue bodies and for banks on how risks involving bank losses can best be managed and reduced.
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Addressing Tax Risks Involving Bank Losses
The OECD has published the comments received on a proposed draft of the new Article 17 of the OECD Model Tax Convention (Artistes and Sportsmen).
The OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation, for tax purposes, of cross-border transactions between associated enterprises. In a global economy where multinational enterprises (MNEs) play a prominent role, transfer pricing is high on the agenda of tax administrators and taxpayers alike. Governments need to ensure that the taxable profits of MNEs are not artificially shifted out of their jurisdictions and that the tax base reported by MNEs in their respective countries reflect the economic activity undertaken therein. For taxpayers, it is essential to limit the risks of economic double taxation that may result from a dispute between two countries on the determination of an arm’s length remuneration for their cross-border transactions with associated enterprises.
After having been originally published in 1979, the OECD Transfer Pricing Guidelines were approved by the OECD Council in their original version in 1995. A limited update was made in 2009, primarily to reflect the adoption, in the 2008 update of the Model Tax Convention, of a new paragraph 5 of Article 25 dealing with arbitration, and of changes to the Commentary on Article 25 on mutual agreement procedures to resolve cross-border tax disputes. In the 2010 edition, Chapters I-III were substantially revised, with new guidance on: the selection of the most appropriate transfer pricing method to the circumstances of the case; the practical application of transactional profit methods (transactional net margin method and profit split method); and on the performance of comparability analyses. Furthermore, a new Chapter IX, on the transfer pricing aspects of business restructurings, was added. Consistency changes were made to the rest of the Guidelines.
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The internationally agreed standard, developed by OECD and non-OECD countries in the context of the OECD’s Global Forum on Taxation and endorsed by G20 Finance Ministers in 2004 and by the UN Committee of Experts on International Co-operation in Tax Matters in October 2008, requires exchange of information on request in all tax matters for the administration and enforcement of domestic tax law without regard to a domestic tax interest
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This document is part of a series of transfer pricing explanatory notes that were drafted by the Secretariat and which are intended to provide a first approach to some of the key topics covered in the Transfer Pricing Guidelines.