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Reports


  • 14-February-2019

    English

    Making Dispute Resolution More Effective - MAP Peer Review Report, Romania (Stage 1) - Inclusive Framework on BEPS: Action 14

    Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The minimum standard is complemented by a set of best practices. The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' stage 1 peer review report. This report reflects the outcome of the stage 1 peer review of the implementation of the Action 14 Minimum Standard by Romania.
  • 14-February-2019

    English

    Making Dispute Resolution More Effective - MAP Peer Review Report, Hungary (Stage 1) - Inclusive Framework on BEPS: Action 14

    Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The minimum standard is complemented by a set of best practices.  The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' stage 1 peer review report. This report reflects the outcome of the stage 1 peer review of the implementation of the Action 14 Minimum Standard by Hungary.
  • 14-February-2019

    English

    Making Dispute Resolution More Effective - MAP Peer Review Report, Slovak Republic (Stage 1) - Inclusive Framework on BEPS: Action 14

    Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The minimum standard is complemented by a set of best practices.  The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' stage 1 peer review report. This report reflects the outcome of the stage 1 peer review of the implementation of the Action 14 Minimum Standard by the Slovak Republic.
  • 14-February-2019

    English

    Prevention of Treaty Abuse - Peer Review Report on Treaty Shopping - Inclusive Framework on BEPS: Action 6

    BEPS Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances, is one of the four BEPS minimum standards that all Inclusive Framework members have committed to implement.This report reflects the outcome of the first peer review of the implementation of the Action 6 minimum standard on treaty shopping as approved by the Inclusive Framework on BEPS. It includes the aggregate results of the review and data on tax treaties concluded by each of the 116 members of the Inclusive Framework on BEPS on 30 June 2018. Chapter 1 provides context of the Action 6 minimum standard, Chapter 2 focuses on the peer review process, Chapter 3 highlights the aggregate results of the peer review and Chapter 4 presents the conclusions and next steps. The annex contains the jurisdictional section for each members of the BEPS Inclusive Framework.
  • 14-February-2019

    English

    Making Dispute Resolution More Effective - MAP Peer Review Report, Greece (Stage 1) - Inclusive Framework on BEPS: Action 14

    Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The minimum standard is complemented by a set of best practices.  The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' stage 1 peer review report. This report reflects the outcome of the stage 1 peer review of the implementation of the Action 14 Minimum Standard by Greece.
  • 14-February-2019

    English

    Making Dispute Resolution More Effective - MAP Peer Review Report, Iceland (Stage 1) - Inclusive Framework on BEPS: Action 14

    Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The minimum standard is complemented by a set of best practices.  The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' stage 1 peer review report. This report reflects the outcome of the stage 1 peer review of the implementation of the Action 14 Minimum Standard by Iceland.
  • 14-February-2019

    English

    Making Dispute Resolution More Effective - MAP Peer Review Report, Turkey (Stage 1) - Inclusive Framework on BEPS: Action 14

    Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The minimum standard is complemented by a set of best practices.The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' stage 1 peer review report. This report reflects the outcome of the stage 1 peer review of the implementation of the Action 14 Minimum Standard by Turkey.
  • 14-February-2019

    English

    Making Dispute Resolution More Effective - MAP Peer Review Report, Estonia (Stage 1) - Inclusive Framework on BEPS: Action 14

    Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The minimum standard is complemented by a set of best practices.The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' stage 1 peer review report. This report reflects the outcome of the stage 1 peer review of the implementation of the Action 14 Minimum Standard by Estonia.
  • 29-January-2019

    English

    Harmful Tax Practices - 2018 Progress Report on Preferential Regimes - Inclusive Framework on BEPS: Action 5

    BEPS Action 5 is one of the four BEPS minimum standards which all Inclusive Framework members have committed to implement. One part of the Action 5 minimum standard relates to preferential tax regimes where a peer review is undertaken to identify features of such regimes that can facilitate base erosion and profit shifting, and therefore have the potential to unfairly impact the tax base of other jurisdictions.This progress report is an update to the 2015 BEPS Action 5 report and the 2017 Progress Report. It contains the results of review of all BEPS Inclusive Framework members’ preferential tax regimes that have been identified since the BEPS Project. The results are reported as at January 2019.In addition, the Inclusive Framework agreed on a new standard for substantial activities requirements for no or only nominal tax jurisdictions. This report includes the details of this new standard and the other work on additions to and revisions of the harmful tax practices framework. Finally it contains next steps for the work on harmful tax practices.
  • 13-December-2018

    English

    Harmful Tax Practices – 2017 Peer Review Reports on the Exchange of Information on Tax Rulings - Inclusive Framework on BEPS: Action 5

    BEPS Action 5 is one of the four BEPS minimum standards which all Inclusive Framework members have committed to implement. One part of the Action 5 minimum standard is the transparency framework for compulsory spontaneous exchange of information on certain tax rulings which, in the absence of transparency, could give rise to BEPS concerns. Over 120 jurisdictions have joined the Inclusive Framework and take part in the peer review to assess their compliance with the transparency framework.Specific terms of reference and a methodology have been agreed for the peer reviews to assess a jurisdiction’s implementation of the minimum standard. The review of the transparency framework assesses jurisdictions against the terms of reference which focus on five key elements: i) information gathering process, ii) exchange of information, iii) confidentiality of the information received; iv) statistics on the exchanges on rulings; and v) transparency on certain aspects of intellectual property regimes. Recommendations are issued where improvements are needed to meet the minimum standard.This report reflects the outcome of the second annual peer review of the implementation of the Action 5 minimum standard and covers 92 jurisdictions. It assesses implementation for the 1 January 2017 – 31 December 2017 period.
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