Publications & Documents


  • 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

    Guidance on Transfer Pricing Aspects of Intangibles

    This document contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation in the area of intangibles. The changes clarify the definition of intangibles and provide guidance for related parties; including transactions involving intangibles and the transfer pricing treatment of local market features and corporate synergies. Some transfer pricing issues relating to intangibles are closely related to other issues that are to be addressed during 2015, most notably in relation to the allocation of risk among MNE group members and recharacterisation of transactions. Because of those interactions some sections of this document are in intermediate form and will be finalised in 2015.

  • 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

    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, 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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  • 8-September-2014

    English, PDF, 509kb

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

    BEPS strategies often take advantage of the interaction between the tax rules of different jurisdictions, so only an internationally co-ordinated effort can effectively respond to this issue. The BEPS Action Plan is based on three core principles: coherence, substance and transparency, and sets forth 15 actions to fundamentally change the rules for the taxation of cross-border profits.

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  • 5-September-2014

    English

    OECD Model Tax Convention on Income and on Capital: An overview of available products

    The OECD Model Tax Convention and the worldwide network of tax treaties based upon it help to avoid the danger of double taxation in the case of cross-border investment.

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