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.
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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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.
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.
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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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.
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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The rules of procedure concerning the signing of the Multilateral Convention on Mutual Assistance in Tax Matters.
The OECD Model Tax Convention provides the basis for the negotiation and interpretation of more than 3000 tax treaties that make up a network that co-ordinate the income and corporate tax systems of most countries with the objective of removing tax barriers to cross-border trade and investment.
This publication is the ninth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. This shorter version contains the full text of the Model Tax Convention on Income and on Capital as accepted on 15 July 2014, but without the historical notes, the detailed list of conventions between OECD member countries and the background reports that are included in the full-length version, which will appear soon. Changes appearing in this edition address such issues as Exchange of Information (Article 26), the meaning of beneficial owner (Aricles 10, 11 and 12), the treatment of sportsment and entertainers (Article 17), treatment of termination payments and other technical issues.
Public comments are invited on request for input on BEPS Action 11 regarding work on establishing methodologies to collect and analyse data on BEPS and the actions to address it.