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…

OECD releases draft update of Model Tax Convention

The OECD Committee on Fiscal Affairs has just released a draft update of the OECD Model Tax Convention. Neither the Committee on Fiscal Affairs nor the OECD Council have yet approved the update, but some significant parts have already been…

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…

OECD makes blanket change to double tax treaties

In November 2016, OECD released a multilateral convention that will affect the application of double tax treaties. The instrument implements the outcomes of the BEPS Action Plan into more than 2 000 tax treaties. A signing ceremony has been planned…

OECD releases a multilateral instrument to modify double taxation treaties

Late in November, more than 100 states concluded negotiations on the wording of a new multilateral convention, which is an important part of the OECD’s action plan against base erosion and profit shifting (BEPS). This multilateral instrument will…

G20/OECD revise their programmes to facilitate dispute resolution between tax administrations

In October, the OECD released key documents that form the basis of the Mutual Agreement Procedure (MAP) peer review and monitoring process under Action 14 of the BEPS Action Plan.