The initial Action 7 discussion draft on PE’s has been replaced by a revised discussion draft, which largely focusses on expanding the scope of the dependent agent rule and narrowing the scope of the “specific activity” PE exemptions as mentioned under the current...
On 6 February 2015 the OECD published three papers addressing different developments in the BEPS Action plan: Action 5: Agreement on modified nexus approach for IP regimes Action 13: Guidance on the implementation of transfer pricing documentation and...
In accordance with the base erosion and profit-shifting (BEPS) project, the OECD on September 16 released its first recommendations to G-20 finance ministers and central bank governors for a coordinated international approach to combat tax avoidance by multinational...
In between 16 and 19 December the OECD published the following public discussion drafts on specific issues under these action plans: Action 4: Limitations on interest deductions Action 8-10: Transfer pricing for risk re-characterization and special...
On 29 October 2014, 51 countries endorsed the new G-20/OECD standard for automatic exchange of financial account information in tax matters by signing a multilateral competent authority agreement, based on the OECD’s “Convention on Mutual Administrative Assistance in...
The Organisation for Economic Co-operation and Development (OECD) has published Public Discussion Drafts on the topics of treaty abuse (14 March), hybrid mismatch arrangements (19 March) and the tax challenges of the digital economy (24 March 2014) in addition to the...