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…
OECD releases Transfer Pricing Guidance on Financial Transactions
The OECD released the long-awaited final version of a report on the pricing of related party financial transactions, which is part of BEPS Action Plans 4, 8-10 and will be implemented into the OECD Transfer Pricing Guidelines. The report focuses on…
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…
Assessing agent’s dependence in the context of permanent establishment
The Supreme Administrative Court (SAC) has described the key defining features of a dependent agent for the purpose of assessing whether a permanent establishment of a foreign entity has started to exist in the Czech Republic. Among its conclusions…
Latest news - April 2019
Last month’s tax and legal news in a few sentences.
SAC on how to interpret double taxation treaties
If a double taxation treaty can be applied, the tax administrator may not automatically use domestic legal regulations to interpret a treaty’s individual concepts but must apply international law principles and the commentaries to the OECD’s Model…
Latest news - September 2018
Last month’s tax and legal news in a few sentences.
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…
Latest news - April 2018
Last month’s tax and legal news in a few sentences.
OECD proposes new disclosure rules
The Common Reporting Standard (CRS) is an approved global standard for the automatic exchange of information between tax authorities of individual states. It aims to prevent tax evasion and money laundering. Within the CRS, selected information on…