The additional guidance resulting sets out high-level general principles, which countries agree are relevant and applicable in attributing profits to PEs in accordance with applicable treaty provisions. It also provides examples on the attribution of profits to certain types of PEs arising from the changes to the PE definition under BEPS Action 7.
Ministers and high-level officials from Barbados, Côte d’Ivoire, Jamaica, Malaysia, Panama and Tunisia have today signed the BEPS Multilateral Convention bringing the total number of signatories to 78. This Convention updates the existing network of bilateral tax treaties and reduces opportunities for tax avoidance by multinational enterprises.
Today, Jersey deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting ("multilateral convention") with the OECD. Subsequently, on 20 December, Curaçao joined the multilateral convention.
The latest edition of the OECD Model Tax Convention, an international instrument which serves as a model for countries concluding bilateral tax conventions, has been released today, incorporating significant changes developed under the OECD/G20 project to address base erosion and profit (BEPS).
On August 1st 2017, interested parties were invited to provide comments on the discussion draft of a toolkit on the Taxation of Offshore Indirect Transfers. The Platform for Collaboration on Tax is grateful to the commentators for their input and now publishes the public comments received during the consultation period.
Over the last 50 years, the OECD led the way on tax issues and has been at the forefront of promoting transparency and co-operation in tax matters. Discover the international state of play with an interactive map presenting key indicators and outcomes of the OECD work on international tax matters, with close to 150 countries and jurisdictions.
On 21 November 2017 the OECD Council approved the contents of the 2017 update to the OECD Model Tax Convention. The update will be incorporated in a revised version of the Model Tax Convention that will be published in the next few months.
Today at the OECD Headquarters in Paris, Nigeria signed two major multilateral instruments: the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) and the CRS Multilateral Competent Authority Agreement (the CRS MCAA). Nigeria becomes the 71st jurisdiction to sign the MLI and the 94th jurisdiction to join the CRS MCAA.
Public comments received on the draft contents of the 2017 Update to the OECD Model Tax Convention
The Platform for Collaboration on Tax – a joint initiative of the IMF, OECD, UN and World Bank Group – is seeking public feedback on a draft toolkit designed to help developing countries tackle the complexities of taxing offshore indirect transfers of assets, a practice by which multinational corporations try to minimise their tax liability.