Publications


  • 5-October-2015

    English

    Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

    The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.

  • 5-October-2015

    English

    Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report

    This report sets out recommendations in the form of building blocks for effective CFC rules. The recommendations are designed to ensure that jurisdictions that choose to implement them, have rules that effectively prevent taxpayers from shifting income into foreign subsidiaries. The report sets out the following six building blocks for the design of effective CFC rules: (1) definition of a CFC, (2) CFC exemptions and threshold requirements, (3) definition of income, (4) computation of income, (5) attribution of income, and (6) prevention and elimination of double taxation. Because each country prioritises policy objectives differently, the recommendations provide flexibility to implement CFC rules that combat BEPS in a manner consistent with the policy objectives of the overall tax system and the international legal obligations of the country concerned.

  • 5-October-2015

    English

    Developing a Multilateral Instrument to Modify Bilateral Tax Treaties, Action 15 - 2015 Final Report

    Drawing on the expertise of public international law and tax experts, this report explores the technical feasibility to develop a multilateral instrument to modify tax treaties so as to efficiently implement the tax treaty-related BEPS measures. The report concludes that such an instrument is desirable and feasible and that negotiations for the multilateral instrument should be convened quickly. Based on this analysis, a mandate has been developed for an ad-hoc group, open to the participation of all countries on an equal footing, to develop the multilateral instrument and open it for signature in 2016.

  • 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

    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

    Health Data Governance - Privacy, Monitoring and Research

    All countries are investing in health data. There are however significant cross-country differences in data availability and use. Some countries stand out for their innovative practices enabling privacy-protective data use while others are falling behind with insufficient data and restrictions that limit access to and use of data, even by government itself. Countries that develop a data governance framework that enables privacy-protective data use will not only have the information needed to promote quality, efficiency and performance in their health systems, they will become a more attractive centre for medical research. After examining the current situation in OECD countries, a multi-disciplinary advisory panel of experts identified eight key data governance mechanisms to maximise benefits to patients and to societies from the collection, linkage and analysis of health data and to, at the same time, minimise risks to the privacy of patients and to the security of health data. These mechanisms include coordinated development of high-value, privacy-protective health information systems, legislation that permits privacy-protective data use, open and transparent public communication, accreditation or certification of health data processors, transparent and fair project approval processes, data de-identification and data security practices that meet legal requirements and public expectations without compromising data utility and a process to continually assess and renew the data governance framework as new data and new risks emerge.

  • 2-October-2015

    English

    Mental Health and Work: Austria

    Tackling mental ill-health of the working-age population is becoming a key issue for labour market and social policies in OECD countries. OECD governments increasingly recognise that policy has a major role to play in keeping people with mental ill-health in employment or bringing those outside of the labour market back to it, and in preventing mental illness. This report on Austria is the eighth in a series of reports looking at how the broader education, health, social and labour market policy challenges identified in Sick on the Job? Myths and Realities about Mental Health and Work (OECD, 2012) are being tackled in a number of OECD countries. It concludes that the Austrian system provides good opportunities in principle for improving labour market inclusion of people with mental ill-health but that structural fragmentation of responsibilities limits the means of the federal government to develop coherent health and work policies. Successful structural reform requires including a range of actors responsible for policy implementation to achieve coordination across institutions and better integrated service delivery.

  • 1-October-2015

    English

    Digital Security Risk Management for Economic and Social Prosperity - OECD Recommendation and Companion Document

    This OECD Recommendation and its Companion Document provide guidance for all stakeholders on the economic and social prosperity dimensions of digital security risk. In an economic context in which the digital environment has become essential to growth and prosperity, well-being and inclusiveness, digital security risk should be considered with respect to the broader economic and social perspective, and its management integrated in stakeholders’ decision making processes.

  • 30-September-2015

    English

    Agricultural Policies in Viet Nam 2015

    This review, undertaken in close co-operation with the Vietnamese Ministry of Agriculture and Rural Development, assesses the performance of Vietnamese agriculture over the last two decades, evaluates Vietnamese agricultural policy reforms, discusses the policy framework for sustainable investment in agriculture and provides recommendations to address key challenges in the future.

    The OECD Food and Agricultural Reviews provide comprehensive assessments, according to different angles, of countries’ agricultural policies, including OECD estimates of the level of support; major reform efforts and their potential impacts; or conduciveness of the broad policy framework to generating the innovation that will improve agricultural productivity sustainably.

  • 28-September-2015

    English

    Drying Wells, Rising Stakes - Towards Sustainable Agricultural Groundwater Use

    Groundwater has provided great benefits to agriculture irrigation in semi-arid OECD countries, but its intensive use beyond recharge in certain regions has depleted resources and generated significant negative environmental externalities. The report provides a characterisation of the diversity of groundwater systems, reviews policies in OECD countries, and proposes a package of recommendations to ensure that groundwater can sustain its services to agriculture and contribute to climate change adaptation.

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