Public comments are invited on the future revision of Chapter IV, “Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes” of the Transfer Pricing Guidelines, and the future revision of Chapter VII, “Special Considerations for Intra-Group Services”, of the Transfer Pricing Guidelines.
Today’s revelations from the “Daphne Project” on the Maltese residence and citizenship by investment schemes underline the crucial importance of the the OECD’s work to ensure that the integrity of the OECD/G20 Common Reporting Standard (CRS) is preserved and that any circumvention is detected and addressed.
Building on BEPS Action 4, this practice note has been prepared by the OECD under a programme of co-operation with the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF), to help guide tax officials on how to strengthen their defences against BEPS. Deadline for comment: 18 May 2018.
The consultation document assessed how these schemes are used in an attempt to circumvent the CRS; identified the types of schemes that present a high risk of abuse; reminded stakeholders of the importance of correctly applying relevant CRS due diligence procedures in order to help prevent such abuse; and explained next steps the OECD will undertake to further address the issue, assisted by public input.
Today, the OECD published a new set of bilateral exchange relationships established under the Common Reporting Standard Multilateral Competent Authority Agreement (CRS MCAA) which for the first time includes activations by Panama. The OECD also released the second edition of the Common Reporting Standard Implementation Handbook.
The Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum) published today nine peer review reports assessing compliance with international standards on tax transparency.
The additional guidance resulting sets out high-level general principles, which countries agree are relevant and applicable in attributing profits to PEs in accordance with applicable treaty provisions. It also provides examples on the attribution of profits to certain types of PEs arising from the changes to the PE definition under BEPS Action 7.
More than 110 countries and jurisdictions have agreed to review two key concepts of the international tax system, responding to a mandate from the G20 Finance Ministers to work on the implications of digitalisation for taxation.
As the BEPS Action 14 continues its efforts to make dispute resolution more timely, effective and efficient, eight more peer review reports have been released today. These eight reports highlight how well jurisdictions are implementing the Action 14 minimum standard as agreed to in the OECD/G20 BEPS Project.
Today, the OECD has issued new model disclosure rules that require lawyers, accountants, financial advisors, banks and other service providers to inform tax authorities of any schemes they put in place for their clients to avoid reporting under the OECD/G20 Common Reporting Standard (CRS) or prevent the identification of the beneficial owners of entities or trusts.