OECD – Transfer Pricing in Brazil: Towards Convergence with the OECD Standard

This report is an outcome of the joint project on transfer pricing between OECD and Receita Federal do Brasil (RFB). It contains the findings of the in-depth analysis of similarities and differences between the transfer pricing framework currently in place in Brazil as compared to the OECD guidance (OECD Transfer Pricing Guidelines for Multinational Enterprise…

OECD/G20 Base Erosion and Profit Shifting Project. HARMFUL TAX PRACTICES – 2017 PEER REVIEW REPORTS ON THE EXCHANGE OF INFORMATION ON TAX RULINGS. INCLUSIVE FRAMEWORK ON BEPS: ACTION 5

OECD/G20 Base Erosion and Profit Shifting Project. HARMFUL TAX PRACTICES – 2017 PEER REVIEW REPORTS ON THE EXCHANGE OF INFORMATION ON TAX RULINGS. INCLUSIVE FRAMEWORK ON BEPS: ACTION 5. The integration of national economies and markets has increased substantially in recent years, putting a strain on the international tax rules, which were designed more than…

OECD – MAP Statistics Reporting Framework. BEPS Action 14. The Report on Action 14: Making Dispute Resolution Mechanisms More Effective (“the 2015 Action 14 Report”) was approved by the OECD Committee of Fiscal Affairs (“CFA”) in September, presented to the OECD Council and endorsed by the G20 Finance Ministers on 8 October 2015. This Report contained a commitment by countries engaged in the work to the implementation of a minimum standard to ensure that they resolve treaty-related disputes in a timely, effective and efficient manner and to have their compliance with the minimum standard reviewed by their peers – i.e. the ot her members of the Forum on Tax Administration MAP Forum (“the FTA MAP Forum”). One of the elements of the minimum standard requires jurisdictions to seek to resolve mutual agreement procedure (“MAP”) cases within an average time frame of 24 months. To monitor compliance with this, jurisdictions’ progress toward meeting this target will be periodically reviewed on the basis of the statistics prepared in accordance with an agreed reporting framework. The 2015 Action 14 Report explains that the reporting framework will include agreed milestones for the initiation and conclusion/closing of a MAP case, as well as other relevant stages of the MAP process. The minimum standard also requires jurisdictions to provide timely and complete reporting of MAP statistics, pursuant to the agreed reporting framework. The agreed reporting framework is set out in this note. Section II describes the MAP process to the extent it is relevant for MAP statistics reporting purposes, in particular focusing on the relevant milestones. Section III sets out the statistics reporting templates for the reporting and publication of MAP case inventory and MAP outcomes, and the average time taken for each of the key stages of the MAP process, including the definition of terms used.

OECD – MAP Statistics Reporting Framework. BEPS Action 14. The Report on Action 14: Making Dispute Resolution Mechanisms More Effective (“the 2015 Action 14 Report”) was approved by the OECD Committee of Fiscal Affairs (“CFA”) in September, presented to the OECD Council and endorsed by the G20 Finance Ministers on 8 October 2015. This Report…

OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors

OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors. Riyadh, Saudi Arabia. February 2020. Overview Over the past 10 years, the G20 has supported multilateral co-operation for a globally fair, sustainable and modern international tax system, which translated in to successful deliverables. Thanks to this momentum, significant progress has taken place to…

OECD – Standard for Automatic Exchange of Financial Account Information in Tax Matters: Implementation Handbook. SECOND EDITION

 The purpose of the CRS Handbook is to assist government officials in the implementation of the Standard for the Automatic Exchange of Financial Account Information in Tax Matters (“Standard”) and to provide a practical overview of the Standard to both the financial sector and the public at-large. The Handbook provides a guide on the necessary…

OECD/G20 Base Erosion and Profit Shifting Project – Public consultation document: Review of Country-by-Country Reporting (BEPS Action 13). 6 February 2020 – 6 March 2020

OECD/G20 Base Erosion and Profit Shifting Project – Public consultation document: Review of Country-by-Country Reporting (BEPS Action 13). 6 February 2020 – 6 March 2020. Action 13 of the OECD/G20 Base Erosion and Profit Shifting Project (BEPS Action 13) established a three-tiered standardised approach to transfer pricing documentation, comprising:

IGF-OECD PROGRAM TO ADDRESS BEPS IN MINING TAX INCENTIVES IN MINING: MINIMISING RISKS TO REVENUE

IGF-OECD PROGRAM TO ADDRESS BEPS IN MINING TAX INCENTIVES IN MINING: MINIMISING RISKS TO REVENUE. SUPPLEMENTARY GUIDANCE: How to Use Financial Modelling to Estimate the Cost of Tax Incentives. Financial models are representations of the real world intended to give useful insight. They can be used to help governments make better-informed decisions, such as whether…