Publications & Documents


  • 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

  • 5-October-2015

    English

    Base Erosion and Profit Shifting

    The OECD base erosion and profit shifting project is looking at whether and why MNEs taxable profits are being allocated to locations different from those where the actual business activity takes place.

  • 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

    BEPS Reports

    Read all the OECD reports related to the base erosion and profit shifting project.

    Related Documents
  • 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.

  • 30-September-2015

    English

    Fifth plenary meeting of the Task Force on Tax and Development

    This event will review progress on tax and development made in 2015, including in relation to the UN Sustainable Development Goals, the Financing for Development Conference, the Addis Tax Initiative, the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project, Exchange of Information for Tax Purposes and Tax Inspectors Without Borders (TIWB).

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  • 26-September-2015

    English

    OECD’s Gurría urges countries to act on UN Sustainable Development Goals

    OECD Secretary-General Angel Gurría today called on all countries to fully engage with the new Sustainable Development Goals (SDGs) and said advanced and emerging economies had a particular responsibility to translate the global goals into national policy and to support developing countries in doing the same.

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