Publications & Documents


  • 16-September-2014

    English

    Developing a Multilateral Instrument to Modify Bilateral Tax Treaties

    This report identifies the issues arising from the development of a multilateral instrument that modifies bilateral tax treaties. Without a mechanism for swift implementation, changes to model tax conventions only widen the gap between the content of these models and the content of actual tax treaties. Developing such a mechanism is necessary not only to tackle base erosion and profit shifting, but also to ensure the sustainability of the consensual framework to eliminate double taxation. This is an innovative approach with no exact precedent in the tax world, but precedents for modifying bilateral treaties with a multilateral instrument exist in various other areas of public international law. Drawing on the knowledge of experts in public international law and taxation, the Report concludes that a multilateral instrument is desirable and feasible, and that negotiations for such an instrument should be convened quickly.

  • 16-September-2014

    English

    Addressing the Tax Challenges of the Digital Economy

    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. These BEPS risks will be addressed by the work on the other Actions in the BEPS Action Plan, which will take the relevant features of the digital economy into account. The report also analyses a number of broader tax challenges raised by the digital economy, and discusses potential options to address them, noting the need for further work during 2015 to evaluate these broader challenges and potential options.

  • 16-September-2014

    English

    Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance

    Preferential regimes continue to be a key pressure area in international taxation. The OECD’s 2013 BEPS report recognises that these need to be dealt with more effectively and the work of the Forum on Harmful Tax Practices (FHTP) needs to be refocused with an emphasis on substance and transparency. This is an interim report that sets out the progress made to date.

  • 16-September-2014

    English

    BEPS 2014 Deliverables

    The OECD Committee on Fiscal Affairs (CFA), bringing together 44 countries on an equal footing (all OECD members, OECD accession countries, and G20 countries), has adopted a first set of seven deliverables described in the Action Plan and due in 2014.

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  • 16-September-2014

    English

    Guidance on Transfer Pricing Documentation and Country-by-Country Reporting

    This document contains revised standards for transfer pricing documentation and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. These new reporting provisions, and the transparency they will encourage, will contribute to the objective of understanding, controlling, and tackling BEPS behaviours. Countries participating in the BEPS project will carefully review the implementation of these new standards and will reassess no later than the end of 2020 whether modifications should be made to require reporting of additional or different data. Effective implementation of the new reporting standards and reporting rules will be essential. Additional work will be undertaken to identify the most appropriate means of filing the required information with and disseminating it to tax administrations.

  • 16-September-2014

    English

    Neutralising the Effects of Hybrid Mismatch Arrangements

    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 1 of the report will be supplemented by a commentary, which will explain the recommended rules and illustrate their application with practical examples. 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.

  • 16-September-2014

    English

    OECD releases first BEPS recommendations to G20 for international approach to combat tax avoidance by multinationals

    The OECD released today its first recommendations for a co-ordinated international approach to combat tax avoidance by multinational enterprises, under the OECD/G20 Base Erosion and Profit Shifting Project designed to create a single set of international tax rules to end the erosion of tax bases and the artificial shifting of profits to jurisdictions to avoid paying tax.

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  • 16-September-2014

    English, PDF, 659kb

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

    The September 2014 update on the BEPS Action Plan, including the delivery of the first set of measures from the BEPS Project as well as enhanced engagement with developing countries.

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  • 15-September-2014

    English

    Accountability and Democratic Governance - Orientations and Principles for Development

    The ability of citizens to demand accountability and more open government is fundamental to good governance. There is growing recognition of the need for new approaches to the ways in which donors support accountability, but no broad agreement on what changed practice looks like. This publication aims to provide more clarity on the emerging practice. Based on four country studies Mali, Mozambique, Peru and Uganda, a survey of donor innovations and cutting-edge analysis in this field, and the findings of a series of special high-level international dialogues on how to best support accountability support to parliaments, political parties, elections and the media. The publication takes the view that a wholesale shift in behaviour is required by parts of the development assistance community - moving outside conventional comfort zones and changing reflexes towards new approaches to risk taking, analysis and programming around systems of accountability and ‘do no harm’ efforts in political engagement.

    This piece is aimed at a range of development practitioners, as well as a wider audience, including civil society actors and citizens around the world who interact with donors working on accountability support.

  • 12-September-2014

    English

    A strategic perspective on the prevention, detection and investigation of international tax crime

    Heads of tax crime investigation in 44 countries, as well as the Financial Action Task Force and World Customs Organisation, have come together this week at Europol Headquarters in the Hague for the second meeting of the OECD Forum of Heads of Tax Crime Investigation.

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