Organization for Economic Co-operation and Development

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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

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

Study Shows Only Four Parties to the OECD Anti-Bribery Convention Actively Enforce Convention

According to a recent study by Transparency International (TI), only four of the 41 Parties of the OECD (Organisation for Economic Co-operation and Development) Anti-Bribery Convention (the “Convention”) are “active”...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

Record Keeping Obligations for BVI Companies, Partnerships, Trusts and Other Organisations

The record keeping obligations applicable to BVI companies and partnerships were amended in November 2012 and again in September 2014. The changes have been introduced following OECD Peer Reviews of the Territory. The Reviews...more

International Tax News - October 2014

AUSTRALIA TO REFORM TAX TREATMENT OF EMPLOYEE STOCK AWARDS: 5 TAKEAWAYS FOR US-BASED COMPANIES - The Australian government has committed to reform the tax treatment of employee stock awards as part of its Industry...more

OECD Countries Agree To Share Tax Information

On October 29, representatives from 51 countries, having met at the Global Forum on Transparency and Exchange of Information for Tax Purposes, agreed to address tax havens in exchange for transparency in tax information....more

New Developments on International Automatic Financial Information Exchange and Disclosure

We last updated our clients and friends in February 2014 (Feb 2014 Memorandum) on issues related to the disclosure and automatic exchange of financial information on an international basis. Since then, the pressure...more

Orwell’s 1984 30 Year Later

Welcome to 1984 30 years later! One of the most famous quotes from George Orwell’s 1984 is “Big Brother is Watching You.”. This quote is more true now than at any time in past. At the just concluded Global Forum on Tax...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

G20 Publishes Report on Effective Approaches to Support Implementation of G20/OECD High-Level Principles on Long-Term Investment...

On September 21, the G20 published a report on effective approaches to support implementation of the G20/Organisation for Economic Co-operation and Development (OECD) high-level principles on long-term investment financing by...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

Monitoring recent Swiss tax developments: key takeaways

In the realm of multinational corporate tax planning, Switzerland has long been a key jurisdiction due to its generally attractive business attributes (solid infrastructure and multilingual, skilled workforce) and competitive...more

International Coordination and Cooperation in Corruption Cases

Global anti-corruption enforcement is fast becoming a complicated affair. No longer can companies just focus on the FCPA, with momentary blips of concern for the UK Bribery Act....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

OECD Issues Report of the Questionnaire on Regulatory Regimes for Manufactured Nanomaterials 2010-2011

On September 16, 2014, the Organization for Economic Cooperation and Development (OECD) published a document entitled Report of the Questionnaire on Regulatory Regimes for Manufactured Nanomaterials 2010-2011. The Report...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

OECD Publishes its Standards for the Automatic Exchange of Information

On July 21, the Organisation for Economic Co-operation and Development (OECD) published its Standard for Automatic Exchange of Financial Account Information in Tax Matters. The report contains the OECD’s model competent...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

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