By Date


  • 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.

  • 5-October-2015

    English

    Making Dispute Resolution Mechanisms More Effective, Action 14 - 2015 Final Report

    Improving dispute resolution mechanisms is an integral component of the work on BEPS. The measures developed under Action 14 of the BEPS Project and contained in this report aim to minimize the risks of uncertainty and unintended double taxation. They do so by ensuring the consistent and proper implementation of tax treaties, including the effective and timely resolution of disputes regarding their interpretation or application through the mutual agreement procedure. Countries have agreed to important changes in their approach to dispute resolution, such as a minimum standard with respect to the resolution of treaty-related disputes. They have committed to its rapid implementation and agreed to ensure its effective implementation through the establishment of a robust peer-based monitoring mechanism.  A large group of countries has also committed to provide for mandatory binding arbitration in their bilateral tax treaties as a mechanism to guarantee that treaty-related disputes will be resolved within a specified timeframe.

  • 5-October-2015

    English

    Addressing the Tax Challenges of the Digital Economy, Action 1 - 2015 Final Report

    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, and shows the expected impact of measures developed across the BEPS Project on these risks.  The report also describes rules and implementation mechanisms to enable efficient collection of value-added tax (VAT) in the country of the consumer in cross-border business-to-consumer transactions, which will help level the playing field between foreign and domestic suppliers. The report also discusses and analyses options to deal with the broader tax challenges raised by the digital economy, noting the need for monitoring developments in the digital economy over time.

  • 5-October-2015

    English

    Mandatory Disclosure Rules, Action 12 - 2015 Final Report

    The lack of timely, comprehensive and relevant information on aggressive tax planning strategies is one of the main challenges faced by tax authorities worldwide. Mandatory disclosure regimes can enable countries to quickly respond to tax risks by providing early access to such information. This report includes an overview of mandatory disclosure regimes, based on the experiences of countries that have such regimes, and sets out recommendations for a modular framework for use by countries wishing to implement or amend mandatory disclosure rules in order to obtain early information on aggressive or abusive tax planning schemes and their users. The recommendations provide the necessary flexibility to balance a country’s need for better, more timely information with the compliance burdens for taxpayers. This report also sets out specific recommendations for rules targeting international tax schemes, as well as for the development and implementation of more effective information exchange and co-operation between tax administrations.

  • 5-October-2015

    English

    Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report

    This report includes changes to the definition of permanent establishment in the OECD Model Tax Convention that will address strategies used to avoid having a taxable presence in a country under tax treaties. These changes will ensure that where the activities that an intermediary exercises in a country are intended to result in the regular conclusion of contracts to be performed by a foreign enterprise, that enterprise will be considered to have a taxable presence in that country unless the intermediary is performing these activities in the course of an independent business. The changes will also restrict the application of a number of exceptions to the definition of permanent establishment to activities that are preparatory or auxiliary nature and will ensure that it is not possible to take advantage of these exceptions by the fragmentation of a cohesive operating business into several small operations; they will also address situations where the exception applicable to construction sites is circumvented through the splitting-up contracts between closely related enterprises.

  • 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, PDF, 561kb

    Policy Brief: Taxing Multinational Enterprises - Base Erosion and Profit Shifting (BEPS) III

    The OECD/G20 Base Erosion and Profit Shifting project aims to close gaps in international tax rules that allow multinational enterprises to legally but artificially shift profits to low or no-tax jurisdictions. The project’s final outputs, delivered in October 2015, represent the most fundamental changes to international tax rules in a century.

  • 26-septembre-2015

    Français

    Le Secrétaire général de l’OCDE, M. Angel Gurría, exhorte les pays à agir pour mettre en œuvre les Objectifs de développement durable

    Le Secrétaire général de l’OCDE, M. Angel Gurría, a appelé aujourd’hui l’ensemble des pays à s’investir pleinement pour donner corps aux nouveaux Objectifs de développement durable (ODD), soulignant que les économies avancées et émergentes avaient une responsabilité particulière, celle de traduire ces objectifs de portée mondiale dans leurs politiques nationales et d’aider les pays en développement à faire de même.

    Documents connexes
  • 21-septembre-2015

    Français

    Rapport accompagnant l'inventaire OCDE des mesures de soutien pour les combustibles fossiles

    Cette publication porte sur l’ensemble des politiques qui soutiennent directement la production ou la consommation de combustibles fossiles dans les pays de l’OCDE et une sélection d’économies partenaires. Elle fournit un complément utile à la base de données en ligne de l’OCDE, qui identifie et estime les transferts budgétaires directs et les dépenses fiscales bénéficiant aux combustibles fossiles, et à partir de laquelle sont tirés des résultats et des indicateurs synthétiques sur le soutien aux combustibles fossiles, ainsi que des recommandations politiques.

    Ce rapport met l’accent sur les problèmes engendrés par les subventions aux combustibles fossiles dans le contexte plus large des efforts politiques entrepris pour réduire les émissions de gaz à effet de serre, passant également en revue les différentes initiatives de réforme prises au niveau international (G-20, APEC, etc.). Il présente en outre la couverture, la méthode et les sources utilisées pour construire la base de données en ligne et examine les limites et restrictions qui s’appliquent dans l’interprétation des données.

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