The OECD's Inclusive Framework on BEPS has released two sets of guidance to give greater certainty to tax administrations and MNE Groups alike on the implementation and operation of Country-by-Country (CbC) Reporting (BEPS Action 13).
This report is an outcome of the joint project on transfer pricing between OECD and Receita Federal do Brasil. It contains the findings of the in-depth analysis of similarities and differences between the transfer pricing framework currently in place in Brazil as compared to the OECD guidance (OECD Transfer Pricing Guidelines for Multinational Enterprise and Tax Administrations).
Brazil has identified a clear pathway for bringing its existing transfer pricing framework into alignment with the international consensus, and is weighing two options – immediate or gradual implementation, according to a new joint report by the OECD and Receita Federal, Brazil’s federal revenue authority (RFB).
The OECD and Brazil’s Receita Federal (RFB) issued a joint statement at the high-level event held on 11 July 2019 in Brasília, Brazil, to present the outcomes of the 15-month work programme carried out by OECD jointly with RFB.
The OECD has just released new transfer pricing country profiles for Chile, Finland and Italy, bringing the total number of countries covered to 55. In addition, the OECD has updated the information contained in the country profiles for Colombia and Israel.
These country profiles focus on countries' domestic legislation regarding key transfer pricing principles, including the arm's length principle, transfer pricing methods, comparability analysis, intangible property, intra-group services, cost contribution agreements, transfer pricing documentation, administrative approaches to avoiding and resolving disputes, safe harbours and other implementation measures.
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Digitalisation has a wide range of implications for taxation, impacting tax policy and tax administration at both the domestic and international level. As a result, the tax policy implications of digitalisation have been at the centre of the recent global debate over whether or not international tax rules continue to be fit for purpose in an increasingly changing environment.
As part of the ongoing work of the Inclusive Framework on BEPS, the OECD is seeking public comments on key issues identified in a public consultation document on possible solutions to the tax challenges arising from the digitalisation of the economy.
On 3 July 2018, interested parties were invited to provide comments on a discussion draft on financial transactions, which deals with follow-up work in relation to Actions 8-10 (“Assure that transfer pricing outcomes are in line with value creation”) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the public comments received.
The Inclusive Framework on BEPS has released additional interpretative guidance to give certainty to tax administrations and MNE Groups alike on the implementation of Country-by-Country (CbC) Reporting (BEPS Action 13).