Action Plan on Base Erosion and Profit Shifting

Action Plan on Base Erosion and Profit Shifting PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264202714
Category :
Languages : en
Pages : 44

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Book Description
This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

Action Plan on Base Erosion and Profit Shifting

Action Plan on Base Erosion and Profit Shifting PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264202714
Category :
Languages : en
Pages : 44

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Book Description
This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

OECD/G20 Base Erosion and Profit Shifting Project Addressing the Tax Challenges of the Digital Economy, Action 1 - 2015 Final Report

OECD/G20 Base Erosion and Profit Shifting Project Addressing the Tax Challenges of the Digital Economy, Action 1 - 2015 Final Report PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264241043
Category :
Languages : en
Pages : 290

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Book Description
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 1.

Tax Challenges Arising from Digitalisation – Interim Report 2018

Tax Challenges Arising from Digitalisation – Interim Report 2018 PDF Author: Collectif
Publisher: OECD
ISBN: 9264301763
Category : Business & Economics
Languages : en
Pages : 260

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Book Description
This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.

OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS

OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264293086
Category :
Languages : en
Pages : 218

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Book Description
This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report PDF Author: OECD
Publisher: OECD Publishing
ISBN: 9264241132
Category :
Languages : en
Pages : 458

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Book Description
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.

Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report

Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report PDF Author: OCDE,
Publisher: OCDE
ISBN: 9789264241466
Category : International business enterprises
Languages : en
Pages : 70

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Book Description
This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach and will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports

Tec(h)tonic Shifts: Taxing the “Digital Economy”

Tec(h)tonic Shifts: Taxing the “Digital Economy” PDF Author: Aqib Aslam
Publisher: International Monetary Fund
ISBN: 1513545973
Category : Business & Economics
Languages : en
Pages : 81

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Book Description
The ever-increasing digitalization of businesses has accelerated the need to address the many shortcomings and unresolved issues within the international corporate income tax system. In particular, the customer or “user”—through their online activities—is now considered by many as being a critical driving force behind the value of digital services. Furthermore, the rapid growth of digital service providers over the last decade has made them an increasingly popular target for special taxes—similar to wealth and solidarity taxes—which can also help mobilize much-needed revenues in the wake of a crisis. This paper argues that a plausible conceptual case can be made to tax the value generated by users under the corporate income tax. However, a number of issues need to be tackled for user-based tax measures to become a reality, which include agreement among countries on whether user value justifies a reallocation of taxing rights, establishing the legal right to tax income derived from user value, as well as an appropriate metric for valuing user-generated data if it is ever to be used as a tax base. Furthermore, attempting to tax only certain types of business is ill-advised, especially as user data is now being exploited widely enough for it to be recognized as an input for almost all businesses. Several options present themselves for consideration—from a modified permanent establishment definition combined with taxation by formulary apportionment, to user-based royalty-type taxes—each with their own merits and misdemeanors.

An Analysis of Actions of the OECD Action Plan on BEPS in the Digital Economy

An Analysis of Actions of the OECD Action Plan on BEPS in the Digital Economy PDF Author: Melanie Keller
Publisher: GRIN Verlag
ISBN: 3668392978
Category : Computers
Languages : en
Pages : 63

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Book Description
Bachelor Thesis from the year 2016 in the subject Communications - Multimedia, Internet, New Technologies, , language: English, abstract: This thesis investigates the various actions presented in the “Action Plan on Base Erosion and Profit Shifting” and their applicability to companies operating in the digital economy. Besides the actions stated in the Organisation for Economic Co-operation and Development’s (OECD) Action Plan other measures against BEPS that can be found in recent literature are analysed and compared. Furthermore, it is examined whether these actions are suitable for preventing tax evasion of ebusinesses acting on a cross-border level. Both, indirect and direct taxation, as well as the concept of permanent establishment (PE) in the context of the digital economy are considered and analysed in this paper. The paper focuses mainly on the taxation of cross-border business transactions in the context of e-business. However, the thesis does not examine the situations of specific countries but primarily utilises a general view on the actions without regional limitations. Taxation of bricks and mortar businesses are not specifically considered, though, parallels to the digital economy may be drawn throughout the thesis.

Neutralising the Effects of Hybrid Mismatch Arrangements

Neutralising the Effects of Hybrid Mismatch Arrangements PDF Author: Oecd
Publisher: OCDE
ISBN: 9789264218796
Category : Business & Economics
Languages : en
Pages : 99

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Book Description
This report sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements. Once translated into domestic law, the recommendations in Part 1 of the report will neutralise the effect of cross-border hybrid mismatch arrangements that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part 1 of the report will be supplemented by a commentary, which will explain the recommended rules and illustrate their application with practical examples. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases. Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.

OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports PDF Author: OECD
Publisher: Org. for Economic Cooperation & Development
ISBN: 9789264241237
Category :
Languages : en
Pages : 186

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Book Description
The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.