As part of continuing efforts to improve the international tax framework and tax certainty, the OECD has released the second round of analyses of individual country efforts to improve dispute resolution mechanisms. These seven peer review reports represent the second round of stage 1 evaluations of how countries are implementing new minimum standards agreed in the OECD/G20 BEPS Project.
The Inclusive Framework welcomes The Bahamas and Zambia, bringing to 110 the total number of countries and jurisdictions participating on an equal footing in the Project.
Today the OECD is releasing a consultation document seeking stakeholder input on model mandatory disclosure rules. The model rules target promoters and service providers with a material involvement in the design, marketing or implementation of a CRS avoidance arrangements or offshore structure. They would require such intermediaries to disclose information on the scheme to their local tax authority.
On August 1st 2017, interested parties were invited to provide comments on the discussion draft of a toolkit on the Taxation of Offshore Indirect Transfers. The Platform for Collaboration on Tax is grateful to the commentators for their input and now publishes the public comments received during the consultation period.
As part of continuing efforts to improve tax transparency and the international tax framework, the OECD has released the first analysis of individual countries' progress in spontaneously exchanging information on tax rulings in accordance with Action 5 of the BEPS package of measures released in October 2015.
The Inclusive Framework on BEPS has released additional guidance to give certainty to tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) Reporting (BEPS Action 13).
On 28 November 2017, an OECD delegation met Bakhyt Sultanov, the Kazakhstan Minister of Finance, in Astana to launch an initiative to assist Kazakhstan in the implementation of the measures to tackle Base Erosion and Profit Shifting (BEPS).
One of the elements of the Action 14 minimum standard requires jurisdictions to seek to resolve mutual agreement procedure (“MAP”) cases within an average timeframe of 24 months. To monitor compliance with this element, members of the Inclusive Framework on BEPS have committed to report their MAP statistics pursuant to an agreed reporting framework.
The OECD is now gathering input for the Stage 1 peer reviews of Australia, Ireland, Israel, Japan, Malta, Mexico, New Zealand and Portugal, and invites taxpayers to submit input on specific issues relating to access to MAP, clarity and availability of MAP guidance and the timely implementation of MAP agreements for each of these jurisdictions using the taxpayer input questionnaire.
On 21 November 2017 the OECD Council approved the contents of the 2017 update to the OECD Model Tax Convention. The update will be incorporated in a revised version of the Model Tax Convention that will be published in the next few months.