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LIVE WEBCAST 
UPDATE ON BEPS PROJECT 
2014 DELIVERABLES AND BEYOND 
16 September 2014 
4:00pm – 5:00pm (CEST)
Pascal Saint-Amans 
Director, Centre for Tax Policy and Administration 
Raffaele Russo 
Head of BEPS Project 
Achim Pross 
Head of International Cooperation and Tax Administration Division 
Marlies de Ruiter 
Head of Tax Treaty, Transfer Pricing and Financial Transactions 
2 
Speakers
Ask questions and comment throughout the webcast 
3 
Join the discussion 
Directly: Enter your question in the space provided 
Via email: CTP.BEPS@oecd.org 
Via Twitter: Send a tweet with the hashtag #BEPS
OVERVIEW
5 
The BEPS Project 
Coherence 
Hybrid Mismatch 
Arrangements (2) 
Interest 
Deductions (4) 
CFC Rules (3) 
Harmful Tax 
Practices (5) 
Substance 
Preventing Tax Treaty 
Abuse (6) 
Avoidance of 
PE Status (7) 
TP Aspects of 
Intangibles (8) 
TP/Risk and 
Capital (9) 
TP/High Risk 
Transactions (10) 
Transparency 
Methodologies and 
Data Analysis (11) 
Disclosure 
Rules (12) 
TP Documentation 
(13) 
Dispute 
Resolution (14) 
Digital Economy (1) 
Multilateral Instrument (15)
 After 12 months of work, committee meetings, online 
collaboration, engagement with developing countries, 
discussion drafts, stakeholders input, and public 
consultations … 
 … The seven 2014 deliverables have been agreed by 
consensus by OECD and G20 countries, together with 
a statement that explains their content and nature. 
 With this first set of deliverables, the OECD/G20 Project 
has gone a long way in achieving consensus on key 
measures to address BEPS. 
6 
Where are we 
in the process?
THE 2014 
DELIVERABLES
 Explanatory Statement 
 3 Reports: 
• two final reports on the Digital Economy (Action 1) and the 
Feasibility of a Multilateral Instrument (Action 15) 
• one interim report on harmful tax competition (Action 5) 
 4 Instruments 
• Hybrid Mismatch Arrangements 
• Treaty Abuse 
• TP Intangibles 
• TP Documentation and CBC template 
8 
The 2014 Deliverables
ACTION 1: 
ADDRESSING THE TAX CHALLENGES 
OF THE DIGITAL ECONOMY
DE and BEPS: 
Key conclusions 
• Not possible to ring-fence digital economy for tax purposes 
• Key features and “new” business models that exacerbate 
BEPS risks identified 
• Those BEPS risks will be addressed by other work in BEPS 
project, which will need to consider specific issues linked to 
digital economy, notably: 
– Action 3 (CFC rules) 
– Action 7 (Artificial Avoidance of PE) 
– Actions 8-10 (Transfer Pricing) 
10
DE and broader tax challenges 
Key conclusions (1) 
• Digital economy also raises broader direct tax 
challenges (nexus, characterisation, and data) as 
well as indirect tax (VAT collection in destination 
country for cross-border B2C transactions) 
• Options discussed (including modifications to 
nexus rules and withholding tax on digital 
goods/services) and agreement on framework for 
evaluation re direct tax challenges 
11
• Collection of VAT in B2C transactions shall be addressed by end of 
2015 through work of WP9 
• Refine potential options re direct tax challenges, and evaluate 
impact of BEPS work on them 
• Consider economic incidence of VAT and CIT and impact on 
potential options 
• If further actions are necessary to address BEPS concerns in digital 
economy, consider limiting application of options for broader 
challenges to situations in which BEPS concerns arise 
• Work will be completed by December 2015 
12 
DE and broader tax challenges 
Key conclusions (2)
ACTION 2: 
NEUTRALISING THE EFFECTS OF 
HYBRID MISMATCH ARRANGEMENTS
• What is a hybrid mismatch arrangement? 
– An arrangement that exploits the different tax treatment in two 
jurisdictions to produce a mismatch in tax outcomes 
– Mismatch is either two deductions for the same payment or a deductible 
payment that is not included in income by the recipient 
• What are we trying to achieve? 
– Recommendations for domestic law changes and changes to OECD 
Model Convention to deal with hybrids. 
– Clear, automatic and comprehensive rules that neutralise the tax 
mismatch without disturbing the commercial or regulatory 
consequences. 
14 
Hybrid mismatches
15 
Overview of key features 
Linking rules 
DN/I 
Instruments / 
entities 
Indirect DN/I 
Instruments / 
entities 
DD Entities only 
Special rule on 
dividend exemption 
for instruments 
General rule: 
deny deduction 
Rule order 
Scope 
Primary rule & defensive rule. 
Controlled groups and structured arrangements. 
Related parties for instruments.
16 
Next steps 
Substantive issues 
1. Application of hybrid instrument rule to : 
• intragroup hybrid regulatory capital 
• certain on-market stock-lending and repos 
2. Further consideration of application of imported 
mismatch rule 
3. Further consideration of whether CFC inclusion 
should be treated as inclusion under rule 
Implementation issues 
Transitional rules and guidance on implementation 
and operation of rules 
Resolution of 
substantive issues 
Finalise 
September 2015 
Develop 
commentary and 
transitional rules
• We have consensus on: 
- Linking rules as a concept and their detailed application. 
- Scope to ensure rules are comprehensive but still administrable by taxpayers and tax 
administrations. 
- Rules that neutralise hybrid mismatches even if counterparty jurisdiction does not 
have them. 
- Rules that ensure application do not lead to double taxation. 
• Rules both reduce transaction costs and tax risks for cross-border investment 
when compared with uncoordinated action. 
• Ongoing work to ensure co-ordination with other Actions 
• Commitment to a second phase of work with a focus on implementation issues. 
17 
Where have we got to?
ACTION 5: 
COUNTERING HARMFUL TAX 
PRACTICES MORE EFFECTIVELY, 
TAKING INTO ACCOUNT 
TRANSPARENCY AND SUBSTANCE
19 
Overview 
Sep. 2014 Sep. 2015 Dec. 2015 
Revamp work of FHTP 
with a focus on 
•Requiring substantial 
activity for all preferential 
regimes 
•Transparency and 
compulsory exchange of 
information on rulings on 
preferential regimes 
•Review of member and 
associate regimes 
Strategy to expand 
participation to non-members 
Consider revision to 
existing criteria
• Update on work on substantial activity as it would apply 
to IP regimes 
– Primary focus on nexus approach 
• Framework for exchanging information on taxpayer 
specific rulings 
– Rulings broadly defined, also cover pre and post 
transaction 
• List of member and associate regimes under review 
20 
Progress report on 
work of FHTP
• Finalise agreement on an approach to substantial 
activity for IP regimes 
• Agree how to apply elaborated substantial activity 
criteria to other, non IP regimes 
• Apply framework on rulings and start to exchange 
information 
• Engage with third countries on participation in FHTP 
• Consider revisions or amendments to the existing 
criteria applied to preferential regimes 
21 
Next steps
ACTION 6: 
PREVENTING THE GRANTING OF 
TREATY BENEFITS IN 
INAPPROPRIATE CIRCUMSTANCES
How does the report 
deal with treaty abuse? 
• Clear statement that treaties should avoid creating opportunities 
for non-taxation or reduced taxation through tax evasion or 
avoidance, including treaty shopping 
• A general treaty anti-abuse rule aimed at arrangements one of 
the principal purposes of which is to obtain treaty benefits 
• A number of specific treaty anti-abuse rules 
• Clarification of the interaction of tax treaties and domestic anti-abuse 
rules 
• Tax policy considerations to be considered before entering into a 
treaty 23
How does the report 
deal with treaty abuse? 
• Specific treaty anti-abuse rules proposed in the report 
– Limitation-on-benefits (LOB) rule to address a large number of treaty 
shopping situations based on the legal nature, ownership in, and general 
activities of, residents of a Contracting State 
– Minimum shareholding period to prevent dividend transfer transactions 
– Changes to Article 13(4) to prevent transactions that circumvent the 
application of that rule dealing with capital gains on shares of immovable 
property companies 
– Changes to the tie-breaker rule for determining the treaty residence of 
dual-resident entities 
– Anti-abuse rule for permanent establishments situated in third States 
24
A minimum standard to 
prevent treaty shopping 
• A key outcome of the report is agreement of a minimum level 
of protection against treaty shopping 
• At a minimum countries should agree to include in their tax 
treaties 
– An express statement that their common intention is to eliminate 
double taxation without creating opportunities for treaty 
shopping, and 
– Either 
• The general treaty anti-abuse rule 
• The LOB rule supplemented by a mechanism that would deal with 
conduit arrangements not already dealt with in tax treaties 
• Both the general treaty anti-abuse rule and the LOB rule 25
Tax policy considerations 
to be considered... 
…before entering into a treaty 
• Report also provides that the OECD Model Tax 
Convention will include a description of key tax 
policy considerations that countries should 
consider before deciding to conclude a treaty 
with another country or when considering 
whether to modify, replace or, as a last resort, 
terminate a treaty 
26
• Model provisions and related Commentary included in the 
report, in particular the LOB rule, are in draft form and need to 
be refined 
• Further work is also needed with respect to 
– the implementation of the minimum standard adopted to address 
treaty shopping and 
– the treaty entitlement of various investment funds 
• It will also be necessary to take account of the interaction 
between tax treaties and the recommendations for the design 
of new domestic anti-abuse rules that may result from the 
work on other parts of the Action Plan 
27 
Action 6: 
Follow-up work
ACTION 8: 
GUIDANCE ON TRANSFER PRICING 
ASPECTS OF INTANGIBLES
• Final guidance: 
– Chapter I of the Transfer Pricing Guidelines expanded to discuss 
• Location savings and other local market features 
• Assembled workforce 
• Group synergies 
– New Chapter VI contains guidance on identifying intangibles and 
on determining arm’s length conditions 
• Comparability in intangibles transactions 
• Transfer pricing methods and use of valuation techniques for intangibles 
transactions 
• Numerous examples 
29 
TP of intangibles: 
Phase 1
• Interim guidance on allocation of returns derived from 
intangibles 
– Legal ownership and contractual arrangements are the starting 
point for the transfer pricing analysis 
– But parties contributing to the development, enhancement, 
maintenance, protection, and exploitation of the intangible must 
be appropriately remunerated. This includes parties performing 
functions, using assets, bearing risks, as well as parties 
controlling such activities. 
30 
TP of intangibles: 
Phase 2
• Guidance is interim because of strong links between 
section on returns derived from intangibles and 2015 
work on risk, recharacterisation, capital and possible 
special measures (Actions 8-10) 
• Guidance will be finalised taking into consideration 
issues such as excessive capitalisation, ‘cash-box’ 
owners of intangibles with low functionality, mere 
contractual allocation of risk, dealing with hard to value 
intangibles 
31 
TP of intangibles: 
Phase 2
ACTION 13: 
GUIDANCE ON TRANSFER PRICING 
DOCUMENTATION AND COUNTRY-BY-COUNTRY 
REPORTING
33 
3-Tiered Approach 
• Master file 
– High-level overview of the MNE group business 
• Local file 
– Detailed information on specific group transactions 
• Country by country report 
– Aggregate, jurisdiction-wide information on global allocation of 
income, taxes paid, indicators of economic activity 
– Useful for transfer pricing risk assessment and for evaluating other 
BEPS-related risks
34 
Content: 
CbC reporting template 
By jurisdiction: 
• Revenues (related party / unrelated) 
• Profit (loss) before income tax 
• Income tax paid (cash basis) and accrued 
• Stated capital and accumulated earnings 
• Number of employees 
• Tangible assets other than cash/ cash equivalents 
By constituent entity : 
• Country of organisation / incorporation (if it differs) 
• Main business activity
• Content of reports finalised, but implementation and especially filing 
and dissemination mechanisms for master file and CbC report to be 
addressed over coming months 
• Options include direct filing to all tax administrations, central filing, 
treaty exchange, technological solutions 
• Major considerations cover: 
– Confidentiality 
– Timeliness 
– Consistency 
– Appropriate usage 
– Phase-in rules? 
35 
Implementation Report
ACTION 15: DEVELOPING A 
MULTILATERAL INSTRUMENT TO 
MODIFY BILATERAL TAX TREATIES
Action 15 report 
Focus on feasibility of use of a multilateral 
instrument to implement BEPS measures 
and modify bilateral tax treaties 
Report drafted with help of experts 
Approved by government representatives 
in CFA 
37
 Based on precedents from various areas other 
than tax, a multilateral instrument is feasible 
 Annex contains a number of examples 
 It is also desirable to ensure the sustainability of 
the consensual framework to eliminate double 
taxation 
 Goal is to expedite and streamline the 
implementation of the measures developed to 
address BEPS and amend tax treaties 
38 
Key Conclusions
 In January 2015, the CFA will consider a draft 
mandate for the negotiation of a multilateral 
instrument (who / what / when / how) 
39 
Next steps
DEVELOPING 
COUNTRIES 
ENGAGEMENT
 BEPS is of major significance due to heavy reliance on 
CIT, but issues may differ 
 Regional consultations, Global Fora and UN facilitated 
input into technical work and informed two-part report 
sent to the G20 Development Working Group 
highlighting priorities 
 Global Forum on Tax Treaties and meeting with the 
UN in Paris next week 
 Plans to strengthen and institutionalise the 
engagement 
41 
Developing countries 
and BEPS
STAKEHOLDERS’ 
INPUT
 462 Comments, 5 Public Consultations, more than 
10.000 webcast viewers, conferences, seminars and 
workshops 
 Consultation will continue in 2014 and 2015 
• First discussion drafts out in Nov/Dec 
• Public consultations in Jan/Feb/March 
 Check the updated stakeholders’ calendar online 
43 
Stakeholders’ input 
very valuable
WHAT’S NEXT?
Work in 2014 and 2015 
 2014 deliverables agreed by consensus, but remain in 
draft form so that outstanding technical issues and 
impact of the 2015 deliverables can be incorporated 
before finalising them. 
 Work on 2015 under way at the level of the subsidiary 
bodies 
45
JOIN THE 
DISCUSSION
Ask questions and comment 
47 
Join the discussion 
Directly: Enter your question in the space provided 
Via email: CTP.BEPS@oecd.org 
Via Twitter: Send a tweet with the hashtag #BEPS
Further Information 
Website: www.oecd.org/tax/beps-2014-deliverables.htm 
Contact: CTP.BEPS@oecd.org 
Tax email alerts: www.oecd.org/oecddirect

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BEPS Webcast #4 - Presentation of 2014 Deliverables

  • 1. LIVE WEBCAST UPDATE ON BEPS PROJECT 2014 DELIVERABLES AND BEYOND 16 September 2014 4:00pm – 5:00pm (CEST)
  • 2. Pascal Saint-Amans Director, Centre for Tax Policy and Administration Raffaele Russo Head of BEPS Project Achim Pross Head of International Cooperation and Tax Administration Division Marlies de Ruiter Head of Tax Treaty, Transfer Pricing and Financial Transactions 2 Speakers
  • 3. Ask questions and comment throughout the webcast 3 Join the discussion Directly: Enter your question in the space provided Via email: CTP.BEPS@oecd.org Via Twitter: Send a tweet with the hashtag #BEPS
  • 5. 5 The BEPS Project Coherence Hybrid Mismatch Arrangements (2) Interest Deductions (4) CFC Rules (3) Harmful Tax Practices (5) Substance Preventing Tax Treaty Abuse (6) Avoidance of PE Status (7) TP Aspects of Intangibles (8) TP/Risk and Capital (9) TP/High Risk Transactions (10) Transparency Methodologies and Data Analysis (11) Disclosure Rules (12) TP Documentation (13) Dispute Resolution (14) Digital Economy (1) Multilateral Instrument (15)
  • 6.  After 12 months of work, committee meetings, online collaboration, engagement with developing countries, discussion drafts, stakeholders input, and public consultations …  … The seven 2014 deliverables have been agreed by consensus by OECD and G20 countries, together with a statement that explains their content and nature.  With this first set of deliverables, the OECD/G20 Project has gone a long way in achieving consensus on key measures to address BEPS. 6 Where are we in the process?
  • 8.  Explanatory Statement  3 Reports: • two final reports on the Digital Economy (Action 1) and the Feasibility of a Multilateral Instrument (Action 15) • one interim report on harmful tax competition (Action 5)  4 Instruments • Hybrid Mismatch Arrangements • Treaty Abuse • TP Intangibles • TP Documentation and CBC template 8 The 2014 Deliverables
  • 9. ACTION 1: ADDRESSING THE TAX CHALLENGES OF THE DIGITAL ECONOMY
  • 10. DE and BEPS: Key conclusions • Not possible to ring-fence digital economy for tax purposes • Key features and “new” business models that exacerbate BEPS risks identified • Those BEPS risks will be addressed by other work in BEPS project, which will need to consider specific issues linked to digital economy, notably: – Action 3 (CFC rules) – Action 7 (Artificial Avoidance of PE) – Actions 8-10 (Transfer Pricing) 10
  • 11. DE and broader tax challenges Key conclusions (1) • Digital economy also raises broader direct tax challenges (nexus, characterisation, and data) as well as indirect tax (VAT collection in destination country for cross-border B2C transactions) • Options discussed (including modifications to nexus rules and withholding tax on digital goods/services) and agreement on framework for evaluation re direct tax challenges 11
  • 12. • Collection of VAT in B2C transactions shall be addressed by end of 2015 through work of WP9 • Refine potential options re direct tax challenges, and evaluate impact of BEPS work on them • Consider economic incidence of VAT and CIT and impact on potential options • If further actions are necessary to address BEPS concerns in digital economy, consider limiting application of options for broader challenges to situations in which BEPS concerns arise • Work will be completed by December 2015 12 DE and broader tax challenges Key conclusions (2)
  • 13. ACTION 2: NEUTRALISING THE EFFECTS OF HYBRID MISMATCH ARRANGEMENTS
  • 14. • What is a hybrid mismatch arrangement? – An arrangement that exploits the different tax treatment in two jurisdictions to produce a mismatch in tax outcomes – Mismatch is either two deductions for the same payment or a deductible payment that is not included in income by the recipient • What are we trying to achieve? – Recommendations for domestic law changes and changes to OECD Model Convention to deal with hybrids. – Clear, automatic and comprehensive rules that neutralise the tax mismatch without disturbing the commercial or regulatory consequences. 14 Hybrid mismatches
  • 15. 15 Overview of key features Linking rules DN/I Instruments / entities Indirect DN/I Instruments / entities DD Entities only Special rule on dividend exemption for instruments General rule: deny deduction Rule order Scope Primary rule & defensive rule. Controlled groups and structured arrangements. Related parties for instruments.
  • 16. 16 Next steps Substantive issues 1. Application of hybrid instrument rule to : • intragroup hybrid regulatory capital • certain on-market stock-lending and repos 2. Further consideration of application of imported mismatch rule 3. Further consideration of whether CFC inclusion should be treated as inclusion under rule Implementation issues Transitional rules and guidance on implementation and operation of rules Resolution of substantive issues Finalise September 2015 Develop commentary and transitional rules
  • 17. • We have consensus on: - Linking rules as a concept and their detailed application. - Scope to ensure rules are comprehensive but still administrable by taxpayers and tax administrations. - Rules that neutralise hybrid mismatches even if counterparty jurisdiction does not have them. - Rules that ensure application do not lead to double taxation. • Rules both reduce transaction costs and tax risks for cross-border investment when compared with uncoordinated action. • Ongoing work to ensure co-ordination with other Actions • Commitment to a second phase of work with a focus on implementation issues. 17 Where have we got to?
  • 18. ACTION 5: COUNTERING HARMFUL TAX PRACTICES MORE EFFECTIVELY, TAKING INTO ACCOUNT TRANSPARENCY AND SUBSTANCE
  • 19. 19 Overview Sep. 2014 Sep. 2015 Dec. 2015 Revamp work of FHTP with a focus on •Requiring substantial activity for all preferential regimes •Transparency and compulsory exchange of information on rulings on preferential regimes •Review of member and associate regimes Strategy to expand participation to non-members Consider revision to existing criteria
  • 20. • Update on work on substantial activity as it would apply to IP regimes – Primary focus on nexus approach • Framework for exchanging information on taxpayer specific rulings – Rulings broadly defined, also cover pre and post transaction • List of member and associate regimes under review 20 Progress report on work of FHTP
  • 21. • Finalise agreement on an approach to substantial activity for IP regimes • Agree how to apply elaborated substantial activity criteria to other, non IP regimes • Apply framework on rulings and start to exchange information • Engage with third countries on participation in FHTP • Consider revisions or amendments to the existing criteria applied to preferential regimes 21 Next steps
  • 22. ACTION 6: PREVENTING THE GRANTING OF TREATY BENEFITS IN INAPPROPRIATE CIRCUMSTANCES
  • 23. How does the report deal with treaty abuse? • Clear statement that treaties should avoid creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance, including treaty shopping • A general treaty anti-abuse rule aimed at arrangements one of the principal purposes of which is to obtain treaty benefits • A number of specific treaty anti-abuse rules • Clarification of the interaction of tax treaties and domestic anti-abuse rules • Tax policy considerations to be considered before entering into a treaty 23
  • 24. How does the report deal with treaty abuse? • Specific treaty anti-abuse rules proposed in the report – Limitation-on-benefits (LOB) rule to address a large number of treaty shopping situations based on the legal nature, ownership in, and general activities of, residents of a Contracting State – Minimum shareholding period to prevent dividend transfer transactions – Changes to Article 13(4) to prevent transactions that circumvent the application of that rule dealing with capital gains on shares of immovable property companies – Changes to the tie-breaker rule for determining the treaty residence of dual-resident entities – Anti-abuse rule for permanent establishments situated in third States 24
  • 25. A minimum standard to prevent treaty shopping • A key outcome of the report is agreement of a minimum level of protection against treaty shopping • At a minimum countries should agree to include in their tax treaties – An express statement that their common intention is to eliminate double taxation without creating opportunities for treaty shopping, and – Either • The general treaty anti-abuse rule • The LOB rule supplemented by a mechanism that would deal with conduit arrangements not already dealt with in tax treaties • Both the general treaty anti-abuse rule and the LOB rule 25
  • 26. Tax policy considerations to be considered... …before entering into a treaty • Report also provides that the OECD Model Tax Convention will include a description of key tax policy considerations that countries should consider before deciding to conclude a treaty with another country or when considering whether to modify, replace or, as a last resort, terminate a treaty 26
  • 27. • Model provisions and related Commentary included in the report, in particular the LOB rule, are in draft form and need to be refined • Further work is also needed with respect to – the implementation of the minimum standard adopted to address treaty shopping and – the treaty entitlement of various investment funds • It will also be necessary to take account of the interaction between tax treaties and the recommendations for the design of new domestic anti-abuse rules that may result from the work on other parts of the Action Plan 27 Action 6: Follow-up work
  • 28. ACTION 8: GUIDANCE ON TRANSFER PRICING ASPECTS OF INTANGIBLES
  • 29. • Final guidance: – Chapter I of the Transfer Pricing Guidelines expanded to discuss • Location savings and other local market features • Assembled workforce • Group synergies – New Chapter VI contains guidance on identifying intangibles and on determining arm’s length conditions • Comparability in intangibles transactions • Transfer pricing methods and use of valuation techniques for intangibles transactions • Numerous examples 29 TP of intangibles: Phase 1
  • 30. • Interim guidance on allocation of returns derived from intangibles – Legal ownership and contractual arrangements are the starting point for the transfer pricing analysis – But parties contributing to the development, enhancement, maintenance, protection, and exploitation of the intangible must be appropriately remunerated. This includes parties performing functions, using assets, bearing risks, as well as parties controlling such activities. 30 TP of intangibles: Phase 2
  • 31. • Guidance is interim because of strong links between section on returns derived from intangibles and 2015 work on risk, recharacterisation, capital and possible special measures (Actions 8-10) • Guidance will be finalised taking into consideration issues such as excessive capitalisation, ‘cash-box’ owners of intangibles with low functionality, mere contractual allocation of risk, dealing with hard to value intangibles 31 TP of intangibles: Phase 2
  • 32. ACTION 13: GUIDANCE ON TRANSFER PRICING DOCUMENTATION AND COUNTRY-BY-COUNTRY REPORTING
  • 33. 33 3-Tiered Approach • Master file – High-level overview of the MNE group business • Local file – Detailed information on specific group transactions • Country by country report – Aggregate, jurisdiction-wide information on global allocation of income, taxes paid, indicators of economic activity – Useful for transfer pricing risk assessment and for evaluating other BEPS-related risks
  • 34. 34 Content: CbC reporting template By jurisdiction: • Revenues (related party / unrelated) • Profit (loss) before income tax • Income tax paid (cash basis) and accrued • Stated capital and accumulated earnings • Number of employees • Tangible assets other than cash/ cash equivalents By constituent entity : • Country of organisation / incorporation (if it differs) • Main business activity
  • 35. • Content of reports finalised, but implementation and especially filing and dissemination mechanisms for master file and CbC report to be addressed over coming months • Options include direct filing to all tax administrations, central filing, treaty exchange, technological solutions • Major considerations cover: – Confidentiality – Timeliness – Consistency – Appropriate usage – Phase-in rules? 35 Implementation Report
  • 36. ACTION 15: DEVELOPING A MULTILATERAL INSTRUMENT TO MODIFY BILATERAL TAX TREATIES
  • 37. Action 15 report Focus on feasibility of use of a multilateral instrument to implement BEPS measures and modify bilateral tax treaties Report drafted with help of experts Approved by government representatives in CFA 37
  • 38.  Based on precedents from various areas other than tax, a multilateral instrument is feasible  Annex contains a number of examples  It is also desirable to ensure the sustainability of the consensual framework to eliminate double taxation  Goal is to expedite and streamline the implementation of the measures developed to address BEPS and amend tax treaties 38 Key Conclusions
  • 39.  In January 2015, the CFA will consider a draft mandate for the negotiation of a multilateral instrument (who / what / when / how) 39 Next steps
  • 41.  BEPS is of major significance due to heavy reliance on CIT, but issues may differ  Regional consultations, Global Fora and UN facilitated input into technical work and informed two-part report sent to the G20 Development Working Group highlighting priorities  Global Forum on Tax Treaties and meeting with the UN in Paris next week  Plans to strengthen and institutionalise the engagement 41 Developing countries and BEPS
  • 43.  462 Comments, 5 Public Consultations, more than 10.000 webcast viewers, conferences, seminars and workshops  Consultation will continue in 2014 and 2015 • First discussion drafts out in Nov/Dec • Public consultations in Jan/Feb/March  Check the updated stakeholders’ calendar online 43 Stakeholders’ input very valuable
  • 45. Work in 2014 and 2015  2014 deliverables agreed by consensus, but remain in draft form so that outstanding technical issues and impact of the 2015 deliverables can be incorporated before finalising them.  Work on 2015 under way at the level of the subsidiary bodies 45
  • 47. Ask questions and comment 47 Join the discussion Directly: Enter your question in the space provided Via email: CTP.BEPS@oecd.org Via Twitter: Send a tweet with the hashtag #BEPS
  • 48. Further Information Website: www.oecd.org/tax/beps-2014-deliverables.htm Contact: CTP.BEPS@oecd.org Tax email alerts: www.oecd.org/oecddirect

Editor's Notes

  1. Larry
  2. Larry
  3. Pascal
  4. Pascal
  5. Larry
  6. Pascal
  7. Larry
  8. Larry
  9. Larry
  10. Larry
  11. Larry
  12. Larry
  13. Larry
  14. The multilateral instrument could also provide the basis for safe exchanges of country-by-country reporting template. Worth mentioning, even though the report is silent about this possibility.
  15. Pascal Saint Amans