BEPS

News & Analysis as of

Hybrid Mismatches – UK Proposals for Implementing the BEPS Recommendations

The United Kingdom made its first substantive commitment arising out of the base erosion and profit shifting (BEPS) initiative on 3 December 2014, with the release of a consultation paper on implementing the agreed G20-...more

Tax Alert: Commissionnaires and Other PE Structures under Scrutiny as Part of BEPS

The OECD has recently published a discussion draft on the portion of its BEPS action plan dealing with permanent establishments and has titled this paper, “Preventing the Artificial Avoidance of PE Status 1 The title itself...more

International Tax News - November 2014

FISCAL STATE AID: ATOMIC ALARM! - Early this month, a group of investigative journalists made public approximately 540 rulings granted by the Luxembourg tax administration to some 340 companies active in a large number...more

OECD proposes curtailing use of commissionaire and other arrangements that aim to avoid PE status

The OECD Focus Group on the Artificial Avoidance of Permanent Establishment (PE) Status recently issued its Proposed Discussion Draft that proposes 14 possible changes to the definition of a PE under Article 5 of the OECD...more

OECD Proposes Changes to the Definition of Permanent Establishment

As previously reported, the Organisation of Economic Co-operation and Development (OECD) published a 15-point Base Erosion and Profit Shifting (BEPS) Action Plan that provided a set of recommendations for a coordinated...more

Action 6 – Preventing the Granting of Treaty Benefits in Inappropriate Circumstances

Action 6 of the BEPS Action Plan identified treaty abuse as one of the most important sources of BEPS concern. The report offers alternative model provisions for the prevention of treaty abuse given constitutional and other...more

Base Erosion and Profit Shifting: The Australian Perspective

In July 2013, the G20 Finance Ministers, including Australia, fully endorsed the base erosion and profit shifting (BEPS) Action Plan. As a result of the Action Plan, the Australian government encouraged a new commitment to...more

Action 5 - Countering Harmful Tax Practices

Action Item 5 of the BEPS Action Plan commits the Forum on Harmful Tax Practices (“FHTP”) to: “revamp the work on harmful tax practices with a priority on improving transparency, including compulsory spontaneous...more

OECD/G20 Base Erosion and Profit Shifting Project

On September 16, 2014, the Organisation for Economic Cooperation and Development (“OECD”) released seven reports addressing certain aspects of the base erosion and profit shifting (“BEPS”) project. The seven BEPS reports...more

BEPS Tail Shouldn’t Wag Global Investment Dog

I spoke recently on a panel in Tokyo on the future of international tax planning after BEPS (the OECD’s & G20’s Action Plan to counter Base Erosion & Profit Shifting). The panel also featured a senior official at the OECD and...more

China’s State Administration of Taxation actively advances the Base Erosion and Profit Shifting 2014 Deliverables

In September 2014, China’s State Administration of Taxation (SAT) released a Chinese translation of the full text of the G20/OECD Base Erosion and Profit Shifting (BEPS) 2014 Deliverables. This was followed in October 2014...more

OECD Publishes Initial Recommendations on BEPS

On September 16, the Organisation of Economic Co-operation and Development (OECD) published a set of recommendations for a coordinated approach to fight tax avoidance by multinational enterprises under the Base Erosion and...more

OECD/BEPS Intangibles Revisions to Change Character, Treatment of Goodwill

Corporations acquiring intangible assets as part of business combination will no longer be able ignore goodwill in their subsequent restructurings and asset transfers. That’s the upshot from tax authorities from around the...more

Corporate and Financial Weekly Digest - Volume IX, Issue 38

In this issue: - SEC Releases Strategic Plan for 2014–2018 - House Passes Bill H.R. 5405 “Promoting Job Creation and Reducing Small Business Burdens Act” - FINRA Board Approves Several Rulemaking Items...more

International Tax News - September 2014

BASE EROSION PROFIT SHIFTING PROJECT RECOMMENDATIONS TO COMBAT TAX AVOIDANCE BY MULTINATIONALS - At the request of the G20 Leaders, the Organisation for Economic Co-Operation and Development (OECD) has been considering...more

Base erosion profit shifting project recommendations to combat tax avoidance by multinationals

At the request of the G20 Leaders, the Organisation for Economic Co-Operation and Development (OECD) has been considering 15 key elements to be addressed by 2015 for a co-ordinated international approach to combat tax...more

International Tax Alert: OECD Releases BEPS Papers

Yesterday saw the release of the first set of deliverables under the OECD’s project on base erosion and profit shifting (BEPS). These constitute the “building blocks” for an internationally agreed and co-ordinated response...more

The Global Crackdown on Profit Shifting

CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your...more

The BEPS Initiative: Redefining International Tax Planning?

Technology companies frequently possess an international tax footprint before expanding their domestic tax footprint. That may soon change as the Organisation for Economic Cooperation and Development (OECD) and its G20...more

The U.S. Tax Code: Love It, Leave It, Or Reform It!

On July 22, 2014, the Senate Finance Committee held a hearing titled, “The U.S. Tax Code: Love It, Leave It, or Reform It!” The general topic of the hearing was international taxation, with a sharp focus on recent and...more

Key issues for asset managers in 2014

In this newsletter - U.S.: - Dodd-Frank Act – Designation of asset managers as systemically important financial institutions - Volcker Rule finalised with a more limited application to covered fund activities...more

Q-and-A on Base Erosion and Profit Shifting

Base Erosion and Profit Shifting (BEPS) is currently the subject of intense discussion among tax professionals worldwide, but it remains a confusing area that is constantly evolving. This Alert highlights the key aims of...more

The OECD’s BEPS Project – A UK update (Part I)

As part of the 2014 UK Budget, HM Treasury and HM Revenue and Customs published a position paper on the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) project. The...more

"Base Erosion and Profit Shifting: Key UK Issues"

Six months have elapsed since the Organisation for Economic Co-operation and Development (OECD) released its 15-point action plan to address Base Erosion and Profit Shifting (BEPS). During this time, OECD has been working...more

2014 Transfer Pricing Resolutions

Happy New Year! It’s time to make your 2014 transfer pricing resolutions: read a good book, learn a new language and, of course, exercise, exercise, exercise. 2013 was a very active year from a transfer pricing...more

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