Reports


  • 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

    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

    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

    BEPS Reports

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

    Related 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.

  • 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.

  • 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.

    Related Documents
  • 1-August-2014

    English, PDF, 1,026kb

    Part 1 of a report to G20 Development Working Group on the impact of BEPS in Low Income Countries

    At the G20’s request, the OECD is leading the development of a strategy to address base erosion and profit shifting (BEPS). The Development Working Group has asked the OECD to draw together the experiences of developing countries and international organisations in a report on the main sources of BEPS in developing countries and how these relate to the OECD/G20 BEPS Action Plan on this issue.

    Related Documents
  • 1-August-2014

    English

    Tax and Benefit Systems: OECD Indicators

    The project "Benefits and Wages" addresses the complicated interactions of tax and benefit systems for different family types and labour market situations and their impact on household incomes and financial work incentives.

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