International taxation rules may change as early as 2023
In a joint declaration, 130 out of the 139 countries united under the OECD for the purpose of implementing the BEPS initiative have agreed on new rules for the international taxation of multinational corporations. The final wording of the rules,…
BEPS 2.0: progress and setbacks
The preparation of BEPS 2.0, new rules for the taxation of the digital economy, has made some progress. Preliminary consensus has been reached on Pillar 1, defining a new rule according to which income will be taxed in the state of sale even if the…
BEPS 2.0: Revolution in international taxation on the horizon
Following up on the Base Erosion and Profit Shifting (BEPS) initiative, the OECD Secretariat published a document containing a new proposal for a unified and global approach to the taxation of the digital economy, BEPS 2.0, introducing a new method…
New Instruction D-34 and translation of TP Guidelines
The financial administration is unifying procedures to determine tax bases affected by transactions between associated enterprises, both domestic and cross-border.
OECD’s discussion draft on the transfer pricing of financial transactions
The discussion draft provides guidance on the pricing of common intra-group financial transactions, such as loans, cash pools, hedging transactions and guarantees.
MLI enters into force
On 1 July 2018, the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent BEPS (‘Multilateral Instrument’ or ‘MLI’) entered into force. On that date, three months have elapsed from the end of the calendar month in which the MLI…
OECD issues release on reviews conducted within BEPS
The Organisation for Economic Cooperation and Development (OECD) has issued a release that updates the results of preferential regime reviews conducted by the Forum on Harmful Tax Practices (FHTP) in connection with Action 5 under the Base Erosion…
2017 OECD Transfer Pricing Guidelines
On 10 July 2017, the long awaited 2017 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017 Transfer Pricing Guidelines) were released. The new edition counting 612 pages replaces the previous Transfer Pricing…