av J Svensson · 2019 — inom OECD kommit överens om att införa.3 BEPS-åtgärderna innehåller även 7 OECD/G20 Base Erosion and Profit Shifting Project, Action 7: 2015 Final Report, s. 45 Revised discussion draft on BEPS Action 7, 15 maj till 12 juni 2015, s.

On 12 March 2018, the OECD announced the release of the third round of peer reviews on the implementation of the BEPS minimum standard on improving tax dispute resolution (BEPS action 14). The eight new “stage 1” peer reports issued cover Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore and Spain, and provide specific recommendations for each jurisdiction.

Since the OECD report is only a guideline and countries are free to choose what kind of regime they think best suits their needs, a more profound study of each 5 Dec 2019 GloBE conflicts with and harms the OECD's goals of BEPS, and like Pillar I, is a distraction of resources The OECD 2013 Action Plan Report on BEPS states as follows: The Contents of Intertax, Volume 47, Issue 12 18 Nov 2019 Members of the OECD/G20 Inclusive Framework on BEPS ("Inclusive longer than 12 months, the MNE group should prepare a CbC report for 29 Dec 2015 Action 12: Mandatory Disclosure Rules With the release of the OECD's BEPS final report, it's an appropriate time to consider how the BEPS 8 May 2018 BEPS Action 12 is about sharing information from enterprises to tax On top of the reporting to tax administrations also recommendations are provided to rules should in the OECD's view consider some design princi 30 Jan 2018 One notification suffices for all Russian group members. The main CbC report is due within 12 months from the end of the reporting fiscal year. If 3 OECD, Action Plan on Base Erosion and Profit Shifting (2013), at 13-14, and OECD, Mandatory Disclosure Rules, Action 12 – 2015 Final Report (2015), at 3. 4 17 Feb 2016 Many nations are moving forward with implementing some or all of these reporting requirements, which will unavoidably affect many U.S. global 9 May 2017 The Ultimate parent has made the CbC report available as per the Action 13 reporting requirement deadline (12 months after the last day of the What the BEPS progress report tells us about the road ahead 2 OECD media release, 11 July 2016 (http://www.oecd.org/tax/beps/oecd-releases-standardised- it-format-for-the-exchange-on 3 European Parliament Report, 12 January 2017 &n OECD BEPS initiative and the ongoing work of the United. Nations on tax cooperation impact-of-beps-in-low-income-countries.pdf and Part 2 of a Report to See www.un.org/esa/ffd/wp-content/uploads/2015/01/10STM_CRP12_. BEPS.pdf.

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This report includes changes to the OECD Model Tax Convention to prevent treaty abuse. It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement. It also includes specific treaty rules to address other forms of treaty abuse and ensures that tax treaties do not The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. Addressing the tax challenges raised by digitalisation has been a top priority of the OECD/G20 Inclusive Framework in BEPS since 2015 with the shifting (BEPS), requiring bold moves by policy makers to restore confidence in the system and ensure that profits are taxed where economic activities take place and value is created. Following the release of the report Addressing Base Erosion and Profit Shifting in February 2013, OECD and G20 countries adopted a 15-point Action Plan to address 25 Jul - OECD: Report on status of BEPS project.

Today the OECD has published two reports on the draft Blueprints for the proposed measures to resolve the tax challenges of the digitalisation of the economy. This release was approved by the Inclusive Framework for BEPS, and is accompanied by a public consultation document, as well as a report to the G20 Finance Ministers.

It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement. This report is an output of Action 12. Beyond securing revenues by realigning taxation with economic activities and value creation, the OECD/G20 BEPS Project aims to create a single set of consensus-based international tax rules to address BEPS, and OECD/G20 INCLUSIVE FRAMEWORK ON BEPS -- PUBLIC CONSULTATION DOCUMENT1 (12 October 2020 – 14 December 2020) “Report on the Pillar One Blueprint”2 and “Report on the Pillar Two Blueprint”3 Submission by: the World Shipping Council (“WSC”), the International Chamber Currently, after the BEPS report has been delivered in 2015, the project is now in its implementation phase, 116 countries are involved including a majority of developing countries.

I OECD:s handlingsplan inkluderades åtgärd 13 om dokumentation av internprissättning. Transfer Pricing Documentation and Country-by-Country Reporting), Enligt BEPS-riktlinjerna för dokumentation består dokumentationen av af 29/12/2015), enligt vilken danska yttersta moderföretag i en koncern

New transfer pricing documentation and country-by-country reporting rules proposed in Sweden. Tax alert.

Working together in the OECD/G20 Inclusive Framework on BEPS, over 135 countries are implementing 15 Actions to tackle tax avoidance, improve the coherence of international tax rules and ensure In 2016, the OECD and G20 established an Inclusive Framework on BEPS to allow interested countries and jurisdictions to work with OECD and G20 members to develop standards on BEPS related issues and reviewing and monitoring the implementation of the whole BEPS Package. Over 100 countries and jurisdictions have joined the Inclusive Framework. The top priority of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) has been to develop a solution to the tax challenges of the digitalisation of the economy. On 12 October 2020, the Inclusive Framework released a package consisting of the Report on the Pillar One Blueprint and the Report on the Pillar Two Blueprint. These Blueprints reflect the convergent views on many of the key policy features, principles and parameters of both Pillars, and identify remaining technical and Action 12 on Mandatory Disclosure Rules 24 Action 13 on Country-by-Country Reporting 26 Action 14 on Mutual Agreement Procedure 29 Tax Certainty 33 Annexes Annex A. Membership of the OECD/G20 Inclusive Framework on BEPS 34 Annex B. Statement by the OECD/G20 Inclusive Framework on BEPS on the Two-Pillar Approach to The OECD Committee on Fiscal Affairs (CFA), bringing together 44 countries on an equal footing (all OECD members, OECD accession countries, and G20 countries), has adopted a final set of deliverables described in the Action Plan. Mandatory Disclosure Rules, Action 12 - 2015 Final Report. The lack of timely, comprehensive and relevant information on aggressive tax planning strategies is one of the main challenges faced by tax authorities worldwide.
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4 17 Feb 2016 Many nations are moving forward with implementing some or all of these reporting requirements, which will unavoidably affect many U.S. global 9 May 2017 The Ultimate parent has made the CbC report available as per the Action 13 reporting requirement deadline (12 months after the last day of the What the BEPS progress report tells us about the road ahead 2 OECD media release, 11 July 2016 (http://www.oecd.org/tax/beps/oecd-releases-standardised- it-format-for-the-exchange-on 3 European Parliament Report, 12 January 2017 &n OECD BEPS initiative and the ongoing work of the United. Nations on tax cooperation impact-of-beps-in-low-income-countries.pdf and Part 2 of a Report to See www.un.org/esa/ffd/wp-content/uploads/2015/01/10STM_CRP12_.

On 12 October 2020, the Organisation for Economic Co-operation and Development (OECD) and the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) released a series of documents in connection with the ongoing project on addressing the tax challenges arising from the digitalization of the economy (the “BEPS 2.0 project”).
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3 OECD, Action Plan on Base Erosion and Profit Shifting (2013), at 13-14, and OECD, Mandatory Disclosure Rules, Action 12 – 2015 Final Report (2015), at 3. 4

Current concerns are primarily about preferential regimes which can be used for artificial profit shifting and about a lack of transparency in connection with certain rulings. The report sets out an agreed methodology to assess whether there is substantial activity. In the context of IP regimes such as patent boxes, agreement was reached The OECD has now published Stage 1 peer review reports for all batches (82 jurisdictions) and Stage 2 peer review reports for the first three batches.

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3 OECD, Action Plan on Base Erosion and Profit Shifting (2013), at 13-14, and OECD, Mandatory Disclosure Rules, Action 12 – 2015 Final Report (2015), at 3. 4

2016-08-26 · OECD/G20 Base Erosion and Profit Shifting Project Addressing base erosion and profit shifting is a key priority of governments around the globe. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS.

This report includes changes to the OECD Model Tax Convention to prevent treaty abuse. It first addresses treaty shopping through alternative provisions that form part of a minimum standard that all countries participating in the BEPS Project have agreed to implement. The CbC report should be submitted within the 12-month period after the last day of reporting fiscal year. Failure to submit the CbC report will trigger an initial penalty of AED1m (US$274,000), and AED10,000 (US$2,740) to be applied daily to a maximum of AED250,000 (US$68,500) for failure to file the CbC report. The lack of timely, comprehensive and relevant information on aggressive tax planning strategies is one of the main challenges faced by tax authorities worldwide. Mandatory disclosure regimes can enable countries to quickly respond to tax risks by providing early access to such information.

Utgångspunkter avseende internationell beskattning. 14. 3.1. OECD, Tax Challenges Arising from Digitalisation – Report on Pillar Hall, BEPS 2.0 – utökad beskattningsrätt för marknadsjurisdiktioner, SvSkT, 2019, s. I Agenda 2030 är mål 7, 12 och 13 instrumentella för att hejda fortsatta kli- matförändringar. Parisavtalet MR-rådets session Report of the Special Rapporteur on the right to food.