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.
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.
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.
This report uses survey data to analyse the levels of co-operation between the authorities combatting serious financial crimes such as tax crimes, bribery corruption, money laundering and terrorism financing. More specifically, it assesses various models for the sharing of Suspicious Transaction Reports by the Financial Intelligence Unit with the tax administration, both for criminal and civil purposes.
Small and medium sized enterprises (SMEs) are important for their contribution to employment, innovation, economic growth and diversity. This report examines the tax treatment of SMEs, the case for SME preferences, and the use of tax preferences and simplification measures for SMEs in thirty-nine OECD and G20 countries. It finds that many of the tax systems examined provide incentives to incorporate and to distribute income in certain types of capital form. Ideally, taxes should be neutral with regard to the business decisions of SMEs, including decisions related to their creation, form and growth. However, certain features of the tax system may disproportionately affect SMEs, for example, the asymmetric treatment of profits and losses, a bias toward debt over corporate equity, and the higher fixed costs of tax and regulatory compliance for small businesses. This report recommends that measures designed to address these concerns be carefully targeted to affected firms and seek to avoid introducing further distortions and complexity.
English, PDF, 3,712kb
This reports consists of two parts. Part I is a report by the OECD Secretary-General regarding (A) the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project; (B) Tax transparency through information exchange; and (C) Tax Policy. Part II is a Progress Report to the G20 by the Global Forum on Transparency and Exchange of Information for Tax Purposes.
English, PDF, 704kb
IMF/OECD Note for G20 meeting in Ankara, 2-6 September 2015
Revenue Statistics in Asian Countries is jointly undertaken by the OECD Centre for Tax Policy and Administration and the OECD Development Centre. It compiles comparable tax revenue statistics for Indonesia, Malaysia, the Philippines, Korea and Japan. The model is the OECD Revenue Statistics database which is a fundamental reference, backed by a well-established methodology, for OECD member countries. Extending the OECD methodology to Asian countries enables comparisons about tax levels and tax structures on a consistent basis, both among Asian economies and between OECD and Asian economies. A special feature in this edition provides country profiles on recent tax administration and related reforms in Indonesia, Malaysia and the Philippines.
Tax Administration 2015, produced under the auspices of the Forum on Tax Administration, is a unique and comprehensive survey of tax administration systems, practices and performance across 56 advanced and emerging economies (including all OECD, EU, and G20 members). Its starting point is the premise that revenue bodies can be better informed and work more effectively together given a broad understanding of the administrative context in which each operates. However, its information content is also likely to be of interest to many external parties (e.g. academics, external audit agencies, regional tax bodies, and international bodies providing technical assistance).
The series identifies some of the fundamental elements of national tax system administration and uses data, analyses and country examples to identify key trends, comparative levels of performance, recent and planned developments, and good practices.
This edition updates performance-related and descriptive material contained in prior editions with new data up to end-fiscal year 2013, and supplements this information on some new topics (e.g. aspects of compliance management and strategic priorities for increased use of on-line services). It also includes coverage of four additional countries (i.e. Costa Rica, Croatia, Morocco, and Thailand).
This handbook provides practical guidance to assist government officials and financial institutions in the implementation of the global Standard for Automatic Exchange of Financial Account Information in Tax Matters.