Keynote: The BEPS Project & the Tax Challenges of the Digital Economy - Raffaele Russo, Head of BEPS Project, The OECD

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The International Business Structuring Association

Keynote Presentation The BEPS Project and the Tax Challenges of the Digital Economy • The overview of the OECD/G20 BEPS project: progress to date and future developments • Tax challenges of the digital economy: how has digitalisation transformed the global economy? • Creating a sustainable regulatory ecosystem for the development of digital economy Raffaele Russo, Head of BEPS Project, The OECD

The BEPS Project and the Tax
Challenges of the Digital Economy
Raffaele Russo
Head of BEPS Project
The OECD

Coherence
Hybrid Mismatch Arrangements
(2)
Harmful Tax
Practices (5)
Interest
Deductions (4)
CFC Rules (3)
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)

‘‘L’urgence est
la colonne vertébrale
de l’action.’’
Quai d’Orsay, Bertrand Tavernier, 2013
© lefigaro.fr

Digital Economy
(63)
Treaty Abuse (79)
TP Intangibles (67)
Hybrids (70)
TP Documentation
(183)
Total comments received: 462
21
7
31
1
2
1
27
6
41
2
3
0
39
6
16
1
5
0
30
3
34
2
1
0
66
21
67
18
9
0
Law & Account Firms
MNE
Business and Lobby
NGO and civil society
Academia
Non Member
Source of comments:
Digital Economy (63)
Treaty Abuse (79)
TP Intangibles (67)
Hybrids (70)
TP Documentation (183)
Consultations and stakeholder input

18
Parent Co
Intermediate
Co 2
Intermediate
Co 1
Ultimate Residence Country
Intermediate Country 2 Intermediate Country 2
Market Country
Local
Activity
Avoid Taxable Presence or
Maximise Deductions / TP Planning
Low or no
Withholding tax
Preferential Regime
Hybrids
TP Planning
Deductible Payments
Ineffective/No CFC Rules
Low or no
Withholding tax
Preferential Regime
Maximise Deductions / TP Planning

© strf.net © techtabz.com
© godependable.com© Sophie Fleury

«… I SAY, DEAR, THIS SURE IS AN IMPRESSIVE LIBRARY.»

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Keynote: The BEPS Project & the Tax Challenges of the Digital Economy - Raffaele Russo, Head of BEPS Project, The OECD

1. The BEPS Project and the Tax Challenges of the Digital Economy Raffaele Russo Head of BEPS Project The OECD

2. Why (BEPS)?

5. What (is BEPS about)?

7. When (is BEPS due)?

8. Coherence Hybrid Mismatch Arrangements (2) Harmful Tax Practices (5) Interest Deductions (4) CFC Rules (3) 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)

10. Where (is BEPS now)?

11. Engagement with developing countries

12. Digital Economy (63) Treaty Abuse (79) TP Intangibles (67) Hybrids (70) TP Documentation (183) Total comments received: 462 21 7 31 1 2 1 27 6 41 2 3 0 39 6 16 1 5 0 30 3 34 2 1 0 66 21 67 18 9 0 Law & Account Firms MNE Business and Lobby NGO and civil society Academia Non Member Source of comments: Digital Economy (63) Treaty Abuse (79) TP Intangibles (67) Hybrids (70) TP Documentation (183) Consultations and stakeholder input

13. 2014 deliverables

14. Let’s talk about the digital economy …

15.

16. BEPS in the digital economy

17.

18. 18 Parent Co Intermediate Co 2 Intermediate Co 1 Ultimate Residence Country Intermediate Country 2 Intermediate Country 2 Market Country Local Activity Avoid Taxable Presence or Maximise Deductions / TP Planning Low or no Withholding tax Preferential Regime Hybrids TP Planning Deductible Payments Ineffective/No CFC Rules Low or no Withholding tax Preferential Regime Maximise Deductions / TP Planning

19. Broader Tax Challenges

21.

22. «… I SAY, DEAR, THIS SURE IS AN IMPRESSIVE LIBRARY.»

23. Options to address these challenges and their relationship with BEPS

24. www.oecd.org/tax/beps.htm #DETAX 24

Keynote: The BEPS Project & the Tax Challenges of the Digital Economy - Raffaele Russo, Head of BEPS Project, The OECD

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Keynote: The BEPS Project & the Tax Challenges of the Digital Economy - Raffaele Russo, Head of BEPS Project, The OECD