Base Erosion and Profit Shifting – A project of the OECD to curb international income tax planning.
The OECD-G20 BEPS Project’s goal is ciclopeous: Making the global tax environment fairer than ever by closing loopholes and adopting rules of international law which would be domesticated simultaneously and uniformly by all participating Nations; and all of that with the aim of making the global enterprise accountable for taxes at source (markets) and home,…
The OECD Public Discussion Draft on BEPS Action 14 (released on 18 December 2014) covers extensively dispute resolution mechanisms and ways to make them more effective. The subject has grown in importance as Mutual Agreement Procedures (“MAP”) have increased significantly especially on transfer pricing cross border adjustments. In this context, the BEPS Discussion Draft states…
The OECD Joint Working Group on Business Restructurings is, in many respects, the precursor to the OECD BEPS project. Unresolved Business Restructuring issues, particularly in relation to permanent establishments, have appeared on the BEPS agenda. One question asked by the Joint Working Group was: Can an agency PE exist if the arrangements entered into did…
The German, French and Italian finance ministers, in a letter to the Commissioner for Taxation and Customs, Pierre Moscovici, as of November 2014 (Financial Times, December 1, 2014), have urged the European Commission to curb aggressive tax planning, base erosion and profit shifting (BEPS) in the EU, mainly caused by the lack of tax harmonization…
