Tax Certainty EBF TAX CONFERENCE Brussels, 22 November Giorgia Maffini. OECD s Centre for Tax Policy and Administration
|
|
- Karin Rose Perry
- 6 years ago
- Views:
Transcription
1 Tax Certainty EBF TAX CONFERENCE 2017 Brussels, 22 November 2017 Giorgia Maffini OECD s Centre for Tax Policy and Administration
2 Tax certainty Tax certainty report 1 delivered to G20 Finance Ministers with IMF, March 2017 We welcome the work on tax certainty conducted by the OECD and the IMF. We acknowledge the report on Tax Certainty submitted to us and encourage jurisdictions to consider voluntarily the practical tools for enhanced tax certainty as proposed in that report, including with respect to dispute prevention and dispute resolution to be implemented within domestic legal frameworks and international tax treaties. We ask the OECD and the IMF to assess progress in enhancing tax certainty in 2018 Chair of the Inclusive Framework has written to all subsidiary bodies
3 The business survey The OECD Business Tax Certainty Survey Between 18 October and 16 December completed responses From firms with global HQ in 62 different jurisdictions And regional HQs in 105 different jurisdictions Wide consultation Survey was developed on basis of Tax Survey developed by OUCBT and ETPF Consultation with business, governments/tax administrations, civil society, academia 3
4 Business survey global HQs Global Headquarters 4
5 Top 20 countries, by HQ of respondents MNEs only
6 Business survey - regional HQs Regional Headquarters 6
7 Turnover (in USD) (1) (2) FT Global 500 Survey (Overall) No. of firms % No. of firms % Over USD 25 b % % Between USD 10b and USD 25b % % Between USD 500m and USD 10b 55 11% % Between USD 50m and USD 500m % Less than USD 50m % NR/No answer % % Total % % Turnover (in USD) FT Global 500 Survey (Overall) in USD million in USD million Mean 47,510 28,295 Median 25, Standard Deviation 62, ,044 Total 17,198,580 17,146,558 % Vs. FT Global % 99.7% 7
8 Respondents by position Current position/responsibilities No. of firms Percentage Director (or equivalent) of the tax department % Senior manager (or equivalent) of international tax issues Senior manager (or equivalent) of specific tax issues % 31 4% Government relations 24 3% Others % Missing % Total number of respondents % 8
9 Respondents by sector C MANUFACTURING 28% 32% K FINANCIAL AND INSURANCE ACTIVITIES G WHOLESALE AND RETAIL TRADE; REPAIR OF MOTOR VEHICLES AND MOTORCYCLES 7% 8% 12% 13% M PROFESSIONAL, SCIENTIFIC AND TECHNICAL ACTIVITIES Missing Other 9
10 Mean Top 5 business factors, by importance for investment Corruption Political Certainty The overall tax environment Current and expected macroeconomic conditions in the country Labour costs 10
11 Top 5 business factors by importance for investment (financial sector only) Corruption Political Certainty Efficient financial markets Availability and quality of digital infrastructure Cost of complying with regulations 11
12 3.9 Top 5 tax factors, by importance for investment Uncertainty about the effective tax rate on profit The anticipated effective tax rate on profit Uncertainty about input tax credits, refunds, place of supply issues for VAT/GST purposes and/or uncertainty about the tax burden of other consumption taxes (e.g. excises, sales taxes, custom duties) The anticipated neutrality of VAT/GST (e.g through the availability of input tax credit, refund and other relief arrangements) or the tax burden of other consumption taxes (e.g. Excises, sales taxes, custom duties) Existence of tax treaties 12
13 Top 5 tax factors by importance for investment (financial sector only) Uncertainty about the effective tax rate on profit The anticipated effective tax rate on profit Existence of tax treaties Uncertainty about input Uncertainty about the tax credits refunds place ability to effectively obtain of supply issues for VAT relief for withholding taxes GST purposes and or uncertainty about the tax burden of other consumption taxes e g excises sales taxes custom duties 13
14 Top 10 sources of tax uncertainty Tax Administration Specific International Dimensions Dispute Resolution Legal Systems 3.0 Considerable bureaucracy to comply with tax legislation, including documentation requirements Unpredictable or inconsistent treatment by the tax authority Inability to achieve early certainty proactively through rulings or other similar mechanisms (e.g Advance Pricing Arrangement) Inconsistencies or conflicts between tax authorities on their interpretations of international tax standards (e.g on transfer pricing or VAT/GST ) Tax legislation not in line with the evolution of new business models Lack of expertise in tax administration on aspects of international taxation Lengthy decision making of the courts tribunals or other relevant bodies Unpredictable and inconsistent treatment by the courts Complexity in the tax legislation (e.g. different definition of permanent establisment for VAT/GST and CIT purposes) Unclear, poorly drafted tax legislation 14
15 Top 5 sources of tax uncertainty (financial sector only) Unpredictable or Inconsistencies or conflicts inconsistent treatment by between tax authorities on the tax authority their interpretations of international tax standards e g on transfer pricing or VAT GST Considerable bureaucracy to comply with tax legislation including documentation requirements Tax legislation not in line with the evolution of new business models Unclear poorly drafted tax legislation 15
16 Top 10 tools to enhance tax certainty Legal Systems Tax Administration Dispute Resolution 16
17 Top 5 tools to enhance tax certainty (financial sector only) Detailed guidance in tax regulations Reduced frequency of changes in the tax legislation Changes in statutory tax system announced in advance Increased transparency from tax administrations in relation to their compliance approaches Reduction of bureaucracy to comply with tax legislation 17
18 Tools to support certainty in international tax Some innovative options received strong support Multilateral Advance Pricing Agreements (APAs ) 36% of respondents say very important and extremely important This figure is 44% when we only consider MNEs Multilateral audits 25% of respondents say very important and extremely important Multilateral cooperative compliance programmes 31% of respondents say very important and extremely important This figure is 36% when we only consider MNEs 18
19 The tax administration survey (1) The OECD/FTA Tax Certainty Survey of Tax Administrations Conducted with members of the Forum on Tax Administration (FTA) Allow tax administrations to respond to results of business survey Is tax certainty a priority for tax administrations? What creates uncertainty for tax administrations? Which measures effective in increasing certainty? 25 OECD and G20 countries 19
20 The tax administration survey (2) The OECD/FTA Tax Certainty Survey of Tax Administrations Tax certainty is a high priority for tax administrations too Over 80% of respondents: very high/extremely high priority for tax administration Tax administrations recognise tax uncertainty important concern for business For tax administration, an important source of tax uncertainty is taxpayers behaviour, especially when involving aggressive tax planning 20
21 N.A. Top 10 sources of tax uncertainty Bureaucracy Business perspective Inconsistent treatment by the tax authority Inconsistent Lengthy interpretation decision making of international of the courts tax standards Tax Administration perspective Complexity in the tax legislation Tax legislation not in line with evolution of new business models Inconsistent treatment by the courts Unclear, poorly drafted tax legislation Tax Administration's lack of expertise on international taxation Inability to achieve early certainty proactively 21
22 4.5 Top 10 tools to enhance tax certainty controlled by the tax administration Reduction of bureaucracy Business perspective Efficient Increased communication transparency in with taxpayers relation to compliance / risk assessment Mutual agreement procedures Tax Administration perspective Timely communication during tax audits Simplified approaches for tax compliance Multilateral APAs Domestic cooperative compliance programmes Unilateral APAs Multilateral cooperative compliance programmes 22
23 Dispute prevention Practical solutions Taxpayer Cooperative compliance programmes bi/multilateral unilateral APA bi/multilateral unilateral Co-ordinated audits (joint, simultaneous abroad) Filing of tax return MAP Arbitration Dispute resolution (BEPS) Tax certainty 23
24 TRACE: common standard for source country taxation Standardised system for claiming withholding tax relief at source on portfolio investments Developed jointly with business and adopted in January 2013 and subsequently aligned to Common Reporting Standard (CRS) in 2015 Based on CRS infrastructure and technical solutions 24
25 TRACE: is it important for investors? OECD 2016 business survey For multinationals investment and location decisions, existence of treaties between countries 2 nd most important feature of the tax system, after certain corporate tax environment and before level of corporate taxation 3 rd most important factor for the financial sector Streamlined and effective withholding tax relief reclaim systems : 59% of the respondents in financial sector rated such factor as very or extremely important to resolve uncertainty 25
26 Context and key drivers Why now? 1. Improves tax certainty 2. Reinforces CRS 3. Lower implementation cost 4. Policy coherence 5. Request from business Improves tax certainty and addresses such uncertainty created by BEPS action 6 Adopting TRACE assists in the implementation of the CRS and makes it stronger With the introduction of the CRS, TRACE can be done more easily and at lower cost One standard for residence country reporting (CRS) combined with one for source country reporting (TRACE); based on same infrastructure for overall efficiency at lowest possible cost to all Addresses clear and consistent request from business, worried about compliance costs 26
27 TRACE: where are we? OECD working on its technical implementation Until recently, actual country implementation on hold: both governments and business busy implementing CRS and FATCA 27
28 Contact details on TRACE Philip KERFS Centre for Tax Policy and Administration 2, rue André Pascal Paris Cedex 16 Tel: + 33 (01) Philip.KERFS@oecd.org 28
29 Contact details Giorgia Maffini Deputy Head of the Tax Policy and Statistics Division Centre for Tax Policy and Administration 2, rue André Pascal Paris Cedex 16 Tel: Giorgia.Maffini@oecd.org 29
IMF and OECD deliver report addressing Tax Certainty, including practical recommendations for countries
27 March 2017 Global Tax Alert IMF and OECD deliver report addressing Tax Certainty, including practical recommendations for countries EY Global Tax Alert Library Access both online and pdf versions of
More informationEBIT
EBIT www.ebit-businesstax.com Comments on the Scoping of the future revision of Chapter IV (administrative approaches) of the OECD s Transfer Pricing Guidelines EBIT s Members at the time of writing this
More informationThe OECD s 3 Major Tax Initiatives
The OECD s 3 Major Tax Initiatives 1. The Global Forum on Transparency and Exchange of Information for Tax Purposes Peer review of ~ 100 countries International standard for transparency and exchange of
More informationMr Piet Battiau Head of Consumption Tax Unit Centre for Tax Policy and Administration OECD 2, rue André Pascal Paris Cedex 16 France
Mr Piet Battiau Head of Consumption Tax Unit Centre for Tax Policy and Administration OECD 2, rue André Pascal 75775 Paris Cedex 16 France Brussels, 30 April 2013 Dear Sir, BUSINESSEUROPE plays a crucial
More informationOECD Mrs Marlies de Ruiter 2, rue André Pascal Paris Cedex 16 Frankreich. Düsseldorf, 16 th January 2015
only via email: taxtreaties@oecd.org OECD Mrs Marlies de Ruiter 2, rue André Pascal 75775 Paris Cedex 16 Frankreich Düsseldorf, 16 th January 2015 642 Invitation for Comments on BEPS Action 14: Make Dispute
More informationTHE TAX POLICY LANDSCAPE SIX YEARS AFTER THE CRISIS: A REVIEW OF RECENT TAX POLICY DEVELOPMENTS
THE TAX POLICY LANDSCAPE SIX YEARS AFTER THE CRISIS: A REVIEW OF RECENT TAX POLICY DEVELOPMENTS Bert Brys, Ph.D. Senior Tax Economist Centre for Tax Policy and Administration Tax revenue developments 36
More informationFoundation for International Taxation Jubilee Conference
Minimising and Resolving International Tax Disputes post-beps Foundation for International Taxation Jubilee Conference Professor Richard Vann Sydney Law School The University of Sydney Page 1 Topics Will
More informationTAX AND INCLUSIVE GROWTH
TAX AND INCLUSIVE GROWTH OECD Global Parliamentary Network David Bradbury Head of the Tax Policy & Statistics Division Centre for Tax Policy & Administration, OECD OECD Conference Centre, Paris 15 February
More informationEuropean Business Initiative on Taxation (EBIT)
European Business Initiative on Taxation (EBIT) Comments on the OECD Public Discussion Draft entitled Make Dispute Resolution Mechanisms More Effective 18 December 2014 16 January 2015 At the time of writing
More informationOverview of OECD Action Plan on Base Erosion and Profit Shifting (BEPS)
Overview of OECD Action Plan on Base Erosion and Profit Shifting (BEPS) Monia Naoum, IBFD Research Associate Emily Muyaa, IBFD Research Associate 18 June 2015 1 Introduction: Globalization and its impact
More informationBusiness sets out key principles for digital tax measures
Media Release Business sets out key principles for digital tax measures Paris, 21 st January 2019 Business at OECD has released a list of eleven principles for designing digital tax measures. At this crucial
More informationApril 30, Re: USCIB Comment Letter on the OECD discussion draft on BEPS Action 3: Strengthening CFC Rules. Dear Mr. Pross, General Comments
April 30, 2015 VIA EMAIL Mr. Achim Pross Head, International Cooperation and Tax Administration Division Center for Tax Policy and Administration (CTPA) Organisation for Economic Cooperation and Development
More informationPhoto credits: Cover Rawpixel.com - Shutterstock.com
Photo credits: Cover Rawpixel.com - Shutterstock.com TABLE OF CONTENTS 5 Table of contents Abbreviations and acronyms... 7 Introduction... 9 Part A Preventing Disputes... 11 [BP.1] Implement bilateral
More informationBEPS Action 14: Make Dispute Resolution Mechanisms More Effective
BEPS Action 14: Make Dispute Resolution Mechanisms More Effective The Organization for Economic Cooperation and Development on December 18, 2014, released a public discussion draft pursuant to Action 14,
More informationRESPONSE TO PUBLIC DISCUSSION DRAFT: MANDATORY DISCLOSURE RULES FOR ADDRESSING CRS AVOIDANCE ARRANGEMENTS AND OFFSHORE STRUCTURES
Dr. Achim Pross Head of the International Co-Operation and Tax Administration Division Centre for Tax Policy and Administration Organisation for Economic Co-operation and Development 2 rue André Pascal
More informationPresentation by Shigeto HIKI
Presentation by Shigeto HIKI Co-chair of Forum on Harmful Tax Practices Director International Tax Policy Division, Tax Bureau Ministry of Finance, Japan The Fifth IMF-Japan High-Level Tax Conference For
More informationTax footprint report 2017
Tax Footprint 2017 Tax footprint report 2017 This tax footprint report is a non-audited report, where Kemira publishes its global tax policy and key tax figures. Kemira s quantitative tax analysis is prepared
More informationBase erosion & profit shifting (BEPS) 25 May 2016
Base erosion & profit shifting (BEPS) 25 May 2016 Introduction Important to distinguish between: Tax avoidance Using legal provisions to minimise tax liability Covers interventions that are referred to
More informationIBFD Course Programme International Tax Planning after BEPS and the MLI
IBFD Course Programme International Tax Planning after BEPS and the MLI Summary Recent developments such as the BEPS project and the Multilateral Instrument in international taxation, but also unilateral
More informationGuidance for Taxpayers on the Mutual Agreement Procedure (Q&A)
Guidance for Taxpayers on the Mutual Agreement Procedure (Q&A) July, 2017 Office of the Mutual Agreement Procedure National Tax Agency, Japan This guidance is to complement the contents of the Commissioner
More informationA. Five Main Issues BEPS documentation 2 International tax issues affecting source countries. 3 Change is Constant
A. Five Main Issues 1 2 3 4 5 BEPS documentation International tax issues affecting source countries. Change is Constant Substantial changes require long periods of time OECD/G20 are still working on major
More informationJOINT AUDIT AND OTHER TOOLS IN THE INTERNATIONAL COOPERATION SCENARIO ILARIA PETRACCA, VALERIA IBELLO REVENUE AGENCY OF ITALY.
JOINT AUDIT AND OTHER TOOLS IN THE INTERNATIONAL COOPERATION SCENARIO ILARIA PETRACCA, VALERIA IBELLO REVENUE AGENCY OF ITALY November JOINT AUDIT AND OTHER TOOLS IN THE INTERNATIONAL COOPERATION SCENARIO
More informationG8/G20 TAXATION ISSUES : Tax Training Day, ODI, London 16 September 2013
G8/G20 TAXATION ISSUES : Tax Training Day, ODI, London 16 September 2013 BASE EROSION AND PROFIT SHIFTING 2 OECD Work on Taxation Focus has historically been on the development of common standards to eliminate
More informationRoundup of Australia s BEPS developments
TaxTalk Insights Global Tax Roundup of Australia s BEPS developments 12 April 2017 In brief Since its presidency of the G20 in 2014, Australia has been at the forefront of efforts to combat tax avoidance
More informationBase Erosion Profit Shifting (BEPS)
Base Erosion Profit Shifting (BEPS) Base Erosion Profit Shifting (BEPS) The world continues to evolve and nations are becoming increasingly connected. Domestic tax laws have not kept pace with the evolution
More informationEU JOINT TRANSFER PRICING FORUM
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTOMS UNION Direct taxation, Tax Coordination, Economic Analysis and Evaluation Company Taxation Initiatives Brussels, June 2013 Taxud/D1/ DOC: JTPF/007/FINAL/2013/EN
More informationLIVE WEBCAST UPDATE ON BEPS PROJECT. 26 May :00pm 2:00pm (CEST)
LIVE WEBCAST UPDATE ON BEPS PROJECT 26 May 2014 1:00pm 2:00pm (CEST) Speakers Pascal Saint-Amans Director, Centre for Tax Policy and Administration Raffaele Russo Head of BEPS Project Marlies de Ruiter
More informationMULTILATERAL STRATEGIC PLAN ON MUTUAL AGREEMENT PROCEDURES: A VISION FOR CONTINUOUS MAP IMPROVEMENT. Preamble
MULTILATERAL STRATEGIC PLAN ON MUTUAL AGREEMENT PROCEDURES: A VISION FOR CONTINUOUS MAP IMPROVEMENT Preamble 1. A convergence of global developments is creating elevated levels of tax risk and uncertainty
More informationPrepared by the CFE Fiscal Committee Submitted to the European Institutions in May 2018
Opinion Statement FC 1/2018 on the European Commission proposal of 21 March 2018 for a Council Directive on the common system of a digital services tax on revenues resulting from the provision of certain
More informationOECD releases final BEPS package
6 October 2015 Tax Flash OECD releases final BEPS package On 5 October 2015, the OECD published the final reports of the OECD/G20 Base Erosion and Profit Shifting ( BEPS ) project, which consist of a package
More informationGlobal Transfer Pricing Review
GLOBAL TRANSFER PRICING SERVICES Global Transfer Pricing Review Czech United Republic Kingdom kpmg.com/gtps TAX 2 Global Transfer Pricing Review United Kingdom KPMG observation HMRC supports the Organisation
More informationMr. Joe Andrus Head of Transfer Pricing Unit Centre for Tax Policy and Administration OECD 2, rue Andre Pascal Paris France.
PricewaterhouseCoopers Aktiengesellschaft Wirtschaftsprüfungsgesellschaft Mr. Joe Andrus Head of Transfer Pricing Unit Centre for Tax Policy and Administration OECD 2, rue Andre Pascal 75775 Paris France
More informationOECD releases France peer review report on implementation of Action 14 Minimum Standards
26 December 2017 Global Tax Alert OECD releases France peer review report on implementation of Action 14 Minimum Standards EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationPrivate sector members' paper outlining corporate tax transfer pricing risk assessment and management approaches.
EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTOMS UNION Direct Taxation, Tax Coordination, Economic Analysis and Evaluation Unit D1 Company Taxation Initiatives Brussels, January 2012 Taxud/D1/
More informationInternational Dispute Resolution: Global Perspectives and Opportunities GW-IRS Annual Tax Institute Washington, DC November 30, 2017
International Dispute Resolution: Global Perspectives and Opportunities 2017 GW-IRS Annual Tax Institute Washington, DC November 30, 2017 Panelists Carol Dunahoo, Partner, Baker & McKenzie LLP (Chair)
More informationBEPS Action 3: Strengthening CFC rules
Achim Pross Head International Co-operation and Tax Administration Division OECD / CTPA 2 rue André Pascal 75775 Paris Cedex 16 By Email CTPCFC@oecd.org Our Ref Your Ref 1 May 2015 Dear Mr Pross BEPS Action
More informationBEPS Country-by-Country Reporting Rules and New Documentation Requirements
BEPS Country-by-Country Reporting Rules and New Documentation Requirements, EY LLP, Couzin Taylor LLP 67 th Annual Tax Conference 67e Conférence fiscale annuelle 2015 Agenda 1. The BEPS project: Action
More informationGeneral comments. William Morris Chair, BIAC Tax Committee Business & Industry Advisory Committee 13/15, Chauseee de la Muette Paris France
William Morris Chair, BIAC Tax Committee Business & Industry Advisory Committee 13/15, Chauseee de la Muette 75016 Paris France Andrew Hickman, Head of Transfer Pricing Unit Centre for Tax Policy and Administration
More informationKPMG LLP 2001 M Street, NW Washington, D.C Comments on the Discussion Draft on Cost Contribution Arrangements
KPMG LLP 2001 M Street, NW Washington, D.C. 20036-3310 Telephone 202 533 3800 Fax 202 533 8500 To Andrew Hickman Head of Transfer Pricing Unit Centre for Tax Policy and Administration OECD From KPMG cc
More informationBEPS ACTION 15. Development of a Multilateral Instrument to Implement the Tax Treaty related BEPS Measures
BEPS ACTION 15 Development of a Multilateral Instrument to Implement the Tax Treaty related BEPS Measures REQUEST FOR INPUT ON THE DEVELOPMENT OF A MULTILATERAL INSTRUMENT TO IMPLEMENT THE TAX TREATY-RELATED
More informationTAX INCENTIVES FOR INVESTMENT: AN OECD COST-BENEFIT ANALYSIS ASSESSMENT FRAMEWORK
TAX INCENTIVES FOR INVESTMENT: AN OECD COST-BENEFIT ANALYSIS ASSESSMENT FRAMEWORK Bert Brys Senior Tax Economist Centre for Tax Policy and Administration LAC Fiscal Forum, COSTA RICA 16-17 June 2015 Introduction
More information5. Ireland is Countering Aggressive Tax Planning
CONTENTS 1. Foreword by the Minister for Finance 2. Introduction 3. Ireland s International Tax Charter 4. Ireland s Corporate Tax Strategy 5. Ireland is Countering Aggressive Tax Planning 6. Conclusion
More informationWORKING PAPER. Financial Counsellors - ECOFIN preparation Presidency Issues Note on 'Tax Certainty in a Changing Environment'
Brussels, 29 March 2017 WK 3787/2017 INIT LIMITE ECOFIN WORKING PAPER This is a paper intended for a specific community of recipients. Handling and further distribution are under the sole responsibility
More informationThe Taxation of Non-standard Work
The Taxation of Non-standard Work OECD-BEIS Conference 9 November 2018 Anna Milanez Economist, OECD Centre for Tax Policy & Administration The Taxation of Non-standard Work: Project Overview This project
More informationMaldives Dispute Resolution Profile. (Last updated: 29 November 2018) General Information
1 Maldives Dispute Resolution Profile (Last updated: 29 November 2018) General Information Maldives tax treaties are available at: https://www.mira.gov.mv/tax_treaties.aspx MAP requests should be made
More informationKenya Dispute Resolution Profile. (Last updated: 15 February 2018) General Information
1 Kenya Dispute Resolution Profile (Last updated: 15 February 2018) General Information Kenya s tax treaties are available at: http://www.treasury.go.ke/avoidanceofdoubletaxation.html MAP request should
More informationGlobal Transfer Pricing Review kpmg.com/gtps
Global Transfer Pricing Review Czech Australia Republic kpmg.com/gtps TAX 2 Global Transfer Pricing Review Australia KPMG observation The transfer pricing landscape in Australia continues to be one of
More informationBEPS Action 14: Making dispute resolution mechanisms more effective
BEPS Action 14: Making dispute resolution mechanisms more effective The Panel Achim Pross, Head, International Cooperation and Tax Administration Division, OECD Doug O Donnell, LB&I Commissioner, IRS Martin
More informationOECD meets with business on base erosion and profit shifting action plan
4 October 2013 OECD meets with business on base erosion and profit shifting action plan Executive summary On 1 October 2013, the Organisation for Economic Cooperation and Development (OECD) held a meeting
More informationPhoto credits: Cover Rawpixel.com - Shutterstock.com
Photo credits: Cover Rawpixel.com - Shutterstock.com TABLE OF CONTENTS 5 Table of contents Abbreviations and acronyms... 7 Introduction... 9 Part A Preventing Disputes... 11 [BP.1] Implement bilateral
More informationParaguay Dispute Resolution Profile. (Last updated: 27 June 2017)
1 Paraguay Dispute Resolution Profile (Last updated: 27 June 2017) General Information Paraguay tax treaties are available at: Under request at the Ministry of Foreign Affairs. MAP request should be made
More informationIncome Tax Workshop Base eroding payments Tax certainty and BEPS... 29
Contents BEPS IMPLEMENTATION... 3 Implementing BEPS1: Minimum Standards (BL)... 3 Implementing BEPS2: Hybrids, Interests, CFCs... 4 BEPS TRANSFER PRICING... 5 The revised Transfer Pricing Guidelines...
More informationRe: Taxand Comments on the Clarification of the Meaning of 'Beneficial Owner' found in Articles 10, 11 and 12 of the OECD Model Tax Convention
14 July 2011 Mr Jeffrey Owens Director, CTPA OECD 2, Rue André Pascal 75775 Paris France Dear Mr Owens, Re: Taxand Comments on the Clarification of the Meaning of 'Beneficial Owner' found in Articles 10,
More informationOECD DISCUSSION DRAFT ON TRANSFER PRICING COMPARABILITY AND DEVELOPING COUNTRIES
Paris: 11 April 2014 OECD DISCUSSION DRAFT ON TRANSFER PRICING COMPARABILITY AND DEVELOPING COUNTRIES Submitted by email: TransferPricing@oecd.org Dear Joe, Please find below BIAC s comments on the OECD
More informationFair and Effective Taxation
1 Fair and Effective Taxation Clear and Easy to Apply deducted at source e.g. on employees consumption taxes not so for self-employed and business Uncertain Based on Abstract Concepts income, residence,
More informationSeptember 14, Dear Mr. VanderWolk,
September 14, 2017 VIA EMAIL Jefferson VanderWolk Head Tax Treaties, Transfer Pricing and Financial Transactions Division Centre for Tax Policy and Administration Organisation for Economic Cooperation
More informationADDITIONAL GUIDANCE ON ATTRIBUTION OF PROFITS TO PERMANENT ESTABLISHMENTS
Tax Treaties, Transfer Pricing and Financial Transactions Division Organisation for Economic Cooperation and Development 2 rue André-Pascal 75775, Paris, Cedex 16 France September 15, 2017 William Morris
More informationEgypt Dispute Resolution Profile. (Last updated: 16 October 2018) General Information
1 Egypt Dispute Resolution Profile (Last updated: 16 October 2018) General Information Egypt tax treaties are available at: http://www.incometax.gov.eg/treaties.asp MAP requests should be made to: Ms.
More informationCORPORATE TAX AND THE DIGITAL ECONOMY
ICAEW REPRESENTATION 12/18 CORPORATE TAX AND THE DIGITAL ECONOMY 2 February ICAEW welcomes the opportunity to comment on the position paper Corporate Tax and the Digital Economy published by HM Treasury
More informationBase Erosion and Profit Sharing Action Plan 11, 12, 14 & 15. Mr. S.P. Singh, Ex-IRS 7th November, 2015
Base Erosion and Profit Sharing Action Plan 11, 12, 14 & 15 Mr. S.P. Singh, Ex-IRS 7th November, 2015 Contents Action 11 - Establishing Methodologies to Collect and Analyze Data on BEPS Action 12 Requiring
More informationOECD DISCUSSION DRAFT: FOLLOW UP WORK ON BEPS ACTION 6, PREVENTING TREATY ABUSE
Marlies de Ruiter Head, Tax Treaties, Transfer Pricing and Financial Transactions Division Centre for Tax Policy and Administration Organisation for Economic Cooperation and Development 2 rue André-Pascal
More informationOECD releases the United Kingdom peer review report on implementation of Action 14 minimum standards
26 October 2017 Global Tax Alert OECD releases the United Kingdom peer review report on implementation of Action 14 minimum standards EY Global Tax Alert Library Access both online and pdf versions of
More informationOECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2009 Edition B 366258 TABLE OF CONTENTS - 5 Table of Contents Preface 11 Glossary 17 Chapter I The Arm's Length Principle
More informationInformal Ministerial Meeting on Responsible Business Conduct. 26 June 2014 OECD Château Room C Paris, France
Informal Ministerial Meeting on Responsible Business Conduct 26 June 2014 OECD Château Room C Paris, France The Global Forum on Responsible Business Conduct (the Global Forum) was launched by the OECD
More informationConsequences of BEPS for the investment climate in each of the Benelux Counties. Chair: Machiel Lambooij. IFA Trilateral Liège 12 June 2015.
Consequences of BEPS for the investment climate in each of the Benelux Counties Chair: Machiel Lambooij IFA Trilateral Liège 12 June 2015 Program 10:15-11:30 Introductions Sandra Knaepen (FOD Financiën)
More informationKorea Dispute Resolution Profile. (Last updated: 02 April 2018) General Information
1 Korea Dispute Resolution Profile (Last updated: 02 April 2018) General Information Korea tax treaties are available at: www.nts.go.kr/eng: Please see ResourcesTax Law/Treaty MAP request should be made
More informationOECD TP Guidelines July 2017 Brief synopsis
OECD TP Guidelines July 2017 Brief synopsis Introduction to the OECD TP Guidelines Snapshot OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations Commonly referred to as
More informationG20 DEVELOPMENT WORKING GROUP
G20 DEVELOPMENT WORKING GROUP A REPORT ON THE ISSUES ARISING FROM THE INDIRECT TRANSFER OF ASSETS TO IDENTIFY POLICY OPTIONS TO TACKLE ABUSIVE CASES, WITH PARTICULAR REFERENCE TO DEVELOPING COUNTRIES CONCEPT
More informationOECD issues Action Plan on Base Erosion and Profit Shifting (BEPS)
22 July 2013 OECD issues Action Plan on Base Erosion and Profit Shifting (BEPS) Executive summary On 19 July 2013, the Organisation for Economic Cooperation and Development (OECD) issued its much-anticipated
More informationA MULTILATERAL AGREEMENT ON INVESTMENT
GENERAL DISTRIBUTION OCDE/GD(95)65 A MULTILATERAL AGREEMENT ON INVESTMENT REPORT BY THE COMMITTEE ON INTERNATIONAL INVESTMENT AND MULTINATIONAL ENTERPRISES (CIME) AND THE COMMITTEE ON CAPITAL MOVEMENTS
More informationSelected Issues in Tax Administration of Japan
Selected Issues in Tax Administration of Japan Mr. Eimon UEDA Deputy Commissioner (International Affairs) National Tax Agency, JAPAN The Fourth IMF-Japan High Level Tax Conference For Asian Countries in
More informationCopenhagen Economics welcomes the opportunity to comment on the OECD s Discussion Draft on BEPS 8-10, Financial transactions, issued on 3 July 2018.
Copenhagen Economics Kungsgatan 38, 5tr 111 35 Stockholm Sweden Tax Treaties, Transfer Pricing and Financial Transactions Division OECD - Centre for Tax Policy and Administration 2, Rue André Pascal 75775
More informationSlovenia Dispute Resolution Profile. (Last updated: 01 May 2018) General Information
1 Slovenia Dispute Resolution Profile (Last updated: 01 May 2018) General Information Slovenia tax treaties are available at: The list of tax treaties, including the number of relevant Official Gazette
More informationWe would like to confirm that have no objections with posting our comments on the OECD website.
Stowarzyszenie Centrum Cen Transferowych ( Transfer Pricing Centre Association) ul. Foksal 10, 00-366 Warsaw, Poland e-mail: kontakt@cct.org.pl Warsaw, 1 October 2013 Working Party No. 6 of the Committee
More informationComments on the Discussion Draft on Transfer Pricing Comparability Data and Developing Countries
Organisation for Economic Cooperation and Development 2, rue Andre Pascal 75775 Paris Cedex 16 France 11 April, 2014 By email: TransferPricing@oecd.org Dear Sirs and Madams, Comments on the Discussion
More informationOECD releases Singapore s peer review report on implementation of Action 14 minimum standard
Transfer Pricing Alert Issue 18 04 April 2018 OECD releases Singapore s peer review report on implementation of Action 14 minimum standard Executive summary On 12 March 2018, the Organisation for Economic
More informationExpanding the Tax Base in Kenya: A Case for Innovation
Expanding the Tax Base in Kenya: A Case for Innovation Presentation by: Robert Waruiru Associate Director, KPMG Advisory Services Limited CCPA-K September 2017 TABLE OF CONTENTS Introduction Trends in
More informationA Guide To Changes In Irish Tax Rules
A Guide To Changes In Irish Tax Rules - The Global Tax Reform Agenda 6 September 2016 THE FACTS YOU NEED TO KNOW ON IRISH TAX CHANGES 1 INTERNATIONAL TAX RULES HAVE BEEN CHANGING - IRELAND HAS BEEN PARTICIPATING
More informationOECD releases Italy peer review report on implementation of Action 14 Minimum Standards
22 December 2017 Global Tax Alert OECD releases Italy peer review report on implementation of Action 14 Minimum Standards EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationIFA MUNICH. Strategic Approaches to Global Transfer Pricing Risk: the use of tax treaties through APA and MAP. 18 January 2018
IFA MUNICH Strategic Approaches to Global Transfer Pricing Risk: the use of tax treaties through APA and MAP 18 January 2018 www.dlapiper.com 86879547 18 January 2018 0 Agenda Current Environment / Current
More informationTax Strategy for The Bahamas as an IFC 2 March 2018
Tax Strategy for The Bahamas as an IFC 2 March 2018 Agenda Tax Strategy for The Bahamas Current global environment Tax strategies of other IFCs Potential impacts of corporate tax Policy considerations
More informationBASE EROSION PROFIT SHARING INITIATIVE THE IMPLICATIONS FOR THE BAHAMAS
BASE EROSION PROFIT SHARING INITIATIVE THE IMPLICATIONS FOR THE BAHAMAS By Ryan Pinder Partner, Graham Thompson International Business & Finance Summit (IBFS) March 2, 2018 Baha Mar Convention Centre Nassau,
More informationTable of Contents. Part One Introduction. Part Two VAT/GST Double (Non-)Taxation and Possible Remedies. Chapter 2: VAT/GST Double (Non-)Taxation 27
Table of Contents Foreword List of Abbreviations vii xvii VAT/GST Model Tax Convention 1 Part One Introduction Chapter 1: Introduction 21 Part Two VAT/GST Double (Non-)Taxation and Possible Remedies Chapter
More informationWilliam Morris Chair, BIAC Tax Committee 13/15, Chaussée de la Muette, Paris. France
Tax Treaties, Transfer Pricing and Financial Transactions Division Organisation for Economic Cooperation and Development 2 rue André-Pascal 75775, Paris, Cedex 16 France February 3, 2017 Ref: DISCUSSION
More informationKorean Tax Update BEPS Implementation
Presentation for KGCCI Korean Tax Update BEPS Implementation May 2018 CONTENTS I. BEPS: Backgrounds What is BEPS? Backgrounds for OECD BEPS Project BEPS Action plans II. BEPS Implementation in Korea I.
More informationDouble Taxation Cases Outside the Transfer Pricing Area
Double Taxation Cases Outside the Transfer Pricing Area December 0 BUSINESSEUROPE a.i.s.b.l AVENUE DE CORTENBERGH 68 BE 000 BRUSSELS BELGIUM TEL + (0) 7 65 FAX + (0) 4 45 E-MAIL MAIN@BUSINESSEUROPE.EU
More informationTransfer pricing. Emerging issues in T.P. Handling KRA audits regarding T.P. Resolving T.P disputes
Transfer pricing Emerging issues in T.P Handling KRA audits regarding T.P Resolving T.P disputes Emerging issues BEPS Effects of BEPS: Loss of revenue by governments and increase in tax administration
More informationLIVE WEBCAST UPDATE ON BEPS PROJECT 2015 DELIVERABLES AND BEYOND. 8 June :00pm 6:00pm (CET)
LIVE WEBCAST UPDATE ON BEPS PROJECT 2015 DELIVERABLES AND BEYOND 8 June 2015 5:00pm 6:00pm (CET) INTRODUCTION Speakers Pascal Saint-Amans Director, Centre for Tax Policy and Administration Achim Pross
More informationInternational Investment Agreements: Strategies and Content
International Investment Agreements: Strategies and Content High level Iraq meeting, Paris, 8 July 2008 Dr. Alexander Böhmer, OECD Private Sector Development Division IRAQ: International Investment Treaty
More informationIMF Revenue Mobilizations and Development Conference: Session on Business Taxation. Alan Carter (ITD) Washington DC, April 18, 2011
IMF Revenue Mobilizations and Development Conference: Session on Business Taxation Alan Carter (ITD) Washington DC, April 18, 2011 International Business Tax Issues - Why are international tax issues important?
More informationBEING A GOOD BUSINESS - OUR APPROACH TO TAX
Coca-Cola European Partners Plc (CCEP) operates in the Fast Moving Consumers Goods (FMCG) sectors in Western Europe. We offer consumers some of the world s leading brands and a wide choice of high quality
More informationOECD releases Germany peer review report on implementation of Action 14 Minimum Standards
21 December 2017 Global Tax Alert OECD releases Germany peer review report on implementation of Action 14 Minimum Standards EY Global Tax Alert Library Access both online and pdf versions of all EY Global
More informationInternational Compliance Assurance Programme. Pilot Handbook. Working Document
International Compliance Assurance Programme Pilot Handbook Working Document This work is published under the responsibility of the Secretary-General of the OECD. The opinions expressed and arguments employed
More informationVOLUME 18, NUMBER 1 >>> JANUARY 2016
VOLUME 18, NUMBER 1 >>> JANUARY 2016 Turkey Abdulkadir Kahraman KPMG, Turkey As a member of the G-20, Turkey is still an attractive market for MNEs. This article addresson Turkey s current tax climate,
More informationTransfer Pricing Perspectives: The new normal: full TransParency. The post BEPS world in the automotive industry
The post BEPS world in the automotive industry 43 The automotive industry has followed a global footprint strategy since many years and it represents now the industry with the highest cross border intercompany
More informationBASE EROSION AND PROFIT SHIFTING ISSUES : THAILAND
BASE EROSION AND PROFIT SHIFTING ISSUES : THAILAND ECOSOC Special Meeting on International Cooperation in Tax Matters 5 June 2014 Phensuk Sangasubana The Revenue Department, Thailand CONTENTS Background
More informationBulgaria Dispute Resolution Profile. (Last updated: 16 December 2016)
1 Bulgaria Dispute Resolution Profile (Last updated: 16 December 2016) General Information Bulgaria tax treaties are available at: http://nra.bg/page?id=427 (Bulgarian) http://www.nap.bg/en/page?id=530
More informationGlobal Transfer Pricing Review kpmg.com/gtps
Global Transfer Pricing Review Czech South Korea Republic kpmg.com/gtps TAX 2 Global Transfer Pricing Review South Korea KPMG observation The Korean Transfer Pricing Regulations, namely, the Law for the
More informationCorporate tax and the digital economy Response by the Chartered Institute of Taxation
Corporate tax and the digital economy Response by the Chartered Institute of Taxation 1 Introduction 1.1 We refer to the government s position paper on Corporate tax and the digital economy published in
More informationContents. Overview of integrity measures Multinational (MNE) anti-avoidance provision... 2
Contents Overview of integrity measures... 1 Multinational (MNE) anti-avoidance provision... 2 GST on digital products and services by offshore suppliers... 3 Status of main changes from G20-OECD Action
More information