Countries: OECD

OECD Publishes Updated Guidance on CbC Reporting

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On 14 October 2022 OECD published updated guidance on CbC reporting. The guidance contains definitions of items in the CbC reporting template – revenue, related parties, tax accrued and paid, fair value accounting, positive and negative figures etc. Issued related to particular reporting entities is also addressed (investment funds, major shareholding, deemed listing provisions and […]

OECD releases new 2022 edition of the OECD Transfer Pricing Guidelines

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On 20 January 2022 the OECD released the 2022 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The OECD Transfer Pricing Guidelines provide guidance on the application of the “arm’s length principle”, which represents the international consensus on the valuation, for income tax purposes, of cross-border transactions between associated enterprises. […]

OECD Guidance on the transfer pricing implications of the COVID-19 pandemic

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Unique economic conditions arising from COVID-19 and government responses to the pandemic have led to practical challenges for the application of the arm’s length principle. For taxpayers applying transfer pricing rules for the financial years impacted by the COVID-19 pandemic and for tax administrations that will be evaluating this application, there is an urgent need […]

New TPG Chapter X on Financial Transactions (and additions to TPG Chapter I) released by OECD

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Today, the OECD has released the report Transfer Pricing Guidance on Financial Transactions. The guidance in the report describes the transfer pricing aspects of financial transactions and includes a number of examples to illustrate the principles discussed in the report. Section B provides guidance on the application of the principles contained in Section D.1 of […]

New Beneficial Ownership Toolkit will help tax administrations tackle tax evasion more effectively

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A beneficial ownership toolkit was released 20. May 2019 in the context of the OECD’s Global Integrity and Anti-Corruption Forum. The toolkit, prepared by the Secretariat of the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes in partnership with the Inter-American Development Bank, is intended to help governments implement the Global […]

Guidance for Tax Administrations on the Application of Guidance on Hard-to-Value Intangibles

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A new report from the OECD contains guidance for tax administration on the application of the approach to hard-to-value intangibles (HTVI), under BEPS Action 8. This new guidance present the principles that should underlie the application of the HTVI approach by tax administration, with the aim of improving consistency and reduce the risk of economic […]

Additional guidance on the attribution of profits to permanent establishments

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The OECD has released additional guidance on the attribution of profits to permanent establishments. This additional guidance sets out high-level general principles for the attribution of profits to permanent establishments arising under Article 5(5), in accordance with applicable treaty provisions, and includes examples of a commissionnaire structure for the sale of goods, an online advertising […]

OECD Model Tax Convention 2017

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A new 2017 edition of the OECD Model Tax Convention has been released today, incorporating significant changes developed under the OECD/G20 project to address base erosion and profit (BEPS). The OECD Model Tax Convention, a model for countries concluding bilateral tax conventions, plays a crucial role in removing tax related barriers to cross border trade […]

OECD: Report on harmful tax practices, 16 October 2017

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The OECD report on harmful tax incentives provides details on reviews of 164 preferential tax regimes. Some preferential tax regimes are considered harmful – where these encourage the erosion of other jurisdictions’ tax bases. All 102 members of the BEPS Inclusive Framework have committed to ensuring that any regimes offered meet the criteria that have […]

OECD Transfer Pricing Guidelines 2017 – New version

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OECD Transfer Pricing Guidelines 2017 – New version The OECD Transfer Pricing Guidelines for Multinational Enterprise and Tax Administrations provide guidance on the application of the “arm’s length principle”, which is the international consensus on transfer pricing, i.e. on the valuation for tax purposes of cross-border transactions between associated enterprises. In a global economy where multinational […]

Signing of the Multilateral Convention to prevent Base Erotion and Profit Shifting “Multilateral Instrument”

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On 7 June 2017, over 70 Ministers and other high-level representatives participated in the signing ceremony of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“Multilateral Instrument” or “MLI”). Signatories include jurisdictions from all continents and all levels of development. A number of jurisdictions have also expressed […]

OECD Report, Making Dispute Resolution Mechanisms More Effective, Action 14 – 2015 Report

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OECD (2015), Making Dispute Resolution Mechanisms More Effective, Action 14 – 2015 Report, OECD/G20 BEPS Project, After two years of work, the 15 actions have now been completed. All the different outputs, including those delivered in an interim form in 2014, have been consolidated into a comprehensive package. The BEPS package of measures represents the […]

OECD’s Manual on Effective Mutual Agreement Procedures (MEMAP)

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The OECD Manual on Effective Mutual Agreement Procedures (MEMAP) is part of a broader project to improve the functioning of existing international tax dispute procedures and to develop supplementary dispute resolution mechanisms. More information about the project, the proposed supplementary dispute resolution mechanism, and other suggested improvements to the Mutual Agreement Procedures (MAP) process can […]