Reports


  • 5-October-2015

    English

    Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

    The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.

  • 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

    Mandatory Disclosure Rules, Action 12 - 2015 Final Report

    The lack of timely, comprehensive and relevant information on aggressive tax planning strategies is one of the main challenges faced by tax authorities worldwide. Mandatory disclosure regimes can enable countries to quickly respond to tax risks by providing early access to such information. This report includes an overview of mandatory disclosure regimes, based on the experiences of countries that have such regimes, and sets out recommendations for a modular framework for use by countries wishing to implement or amend mandatory disclosure rules in order to obtain early information on aggressive or abusive tax planning schemes and their users. The recommendations provide the necessary flexibility to balance a country’s need for better, more timely information with the compliance burdens for taxpayers. This report also sets out specific recommendations for rules targeting international tax schemes, as well as for the development and implementation of more effective information exchange and co-operation between tax administrations.

  • 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

    Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report

    This report includes changes to the definition of permanent establishment in the OECD Model Tax Convention that will address strategies used to avoid having a taxable presence in a country under tax treaties. These changes will ensure that where the activities that an intermediary exercises in a country are intended to result in the regular conclusion of contracts to be performed by a foreign enterprise, that enterprise will be considered to have a taxable presence in that country unless the intermediary is performing these activities in the course of an independent business. The changes will also restrict the application of a number of exceptions to the definition of permanent establishment to activities that are preparatory or auxiliary nature and will ensure that it is not possible to take advantage of these exceptions by the fragmentation of a cohesive operating business into several small operations; they will also address situations where the exception applicable to construction sites is circumvented through the splitting-up contracts between closely related enterprises.

  • 5-October-2015

    English

    BEPS Reports

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

    Related Documents
  • 21-September-2015

    English

    OECD Companion to the Inventory of Support Measures for Fossil Fuels 2015

    This publication is concerned with all policies that directly support the production or consumption of fossil fuels in OECD countries and in a selection of partner economies. It provides a useful complement to the online OECD database that identifies and estimates direct budgetary transfers and tax expenditures benefitting fossil fuels, and from which it derives summary results and indicators on support to fossil fuels, as well as policy recommendations.

    This report emphasises the problems that fossil-fuel subsidies cause in the context of broader policy efforts for mitigating greenhouse-gas emissions, and reviews the various reform initiatives that have already been taken at the international level (G-20, APEC, etc.). In addition, it presents the coverage, method and data sources used for constructing the online database, and further discusses caveats and data interpretation.

  • 17-September-2015

    English

    Improving Co-operation between Tax and Anti-Money Laundering Authorities: Access by tax administrations to information held by financial intelligence units for criminal and civil purposes

    This report uses survey data to analyse the levels of co-operation between the authorities combatting serious financial crimes such as tax crimes, bribery corruption, money laundering and terrorism financing. More specifically, it assesses various models for the sharing of Suspicious Transaction Reports by the Financial Intelligence Unit with the tax administration, both for criminal and civil purposes.

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  • 5-September-2015

    English

    Taxation of SMEs in OECD and G20 Countries

    Small and medium sized enterprises (SMEs) are important for their contribution to employment, innovation, economic growth and diversity. This report examines the tax treatment of SMEs, the case for SME preferences, and the use of tax preferences and simplification measures for SMEs in thirty-nine OECD and G20 countries. It finds that many of the tax systems examined provide incentives to incorporate and to distribute income in certain types of capital form. Ideally, taxes should be neutral with regard to the business decisions of SMEs, including decisions related to their creation, form and growth. However, certain features of the tax system may disproportionately affect SMEs, for example, the asymmetric treatment of profits and losses, a bias toward debt over corporate equity, and the higher fixed costs of tax and regulatory compliance for small businesses. This report recommends that measures designed to address these concerns be carefully targeted to affected firms and seek to avoid introducing further distortions and complexity.

  • 5-September-2015

    English, PDF, 3,712kb

    OECD Secretary-General's tax report to G20 Finance Ministers and Central Bank Governors (September 2015)

    This reports consists of two parts. Part I is a report by the OECD Secretary-General regarding (A) the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project; (B) Tax transparency through information exchange; and (C) Tax Policy. Part II is a Progress Report to the G20 by the Global Forum on Transparency and Exchange of Information for Tax Purposes.

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