OECD’s ACTION PLAN ON BASE EROSION AND PROFIT SHIFTING (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

BACKGROUND BRIEF - INCLUSIVE FRAMEWORK FOR BEPS IMPLEMENTATION (MARCH 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

2015 BEPS Deliverables, which were published on October 5, 2015:

 

·        Addressing the Tax Challenges of the Digital Economy, Action 1 - 2015 Final Report; 

·        Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report;

·        Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report;

·        Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2015 Final Report;

·        Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance, Action 5 - 2015 Final Report;

·        Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report;

·        Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report;

·        Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports;

·        Measuring and Monitoring BEPS, Action 11 - 2015 Final Report;

·        Mandatory Disclosure Rules, Action 12 - 2015 Final Report;

·        Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report;

·        Making Dispute Resolution Mechanisms More Effective, Action 14 - 2015 Final Report;

·        Developing a Multilateral Instrument to Modify Bilateral Tax Treaties, Action 15 - 2015 Final Report.

 

OECD/G20 Base Erosion and Profit Shifting Project - Explanatory Statement 2015 Final Reports as issued by the OECD (In English, Spanish, French or German);

 

Previous documents:

 

ACTION 1

Address the tax challenges of the digital economy

 

• OECD/G20 BASE EROSION AND PROFIT SHIFTING PROJECT – ADDRESSING THE TAX CHALLENGES OF THE DIGITAL ECONOMY - ACTION 1: 2014 DELIVERABLE (SEPTEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

   

• PUBLIC DISCUSSION DRAFT BEPS ACTION 1: ADDRESS THE TAX CHALLENGES OF THE DIGITAL ECONOMY (MARCH 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments received on Public Discussion Draft – BEPS ACTION 1: ADDRESS THE TAX CHALLENGES OF THE DIGITAL ECONOMY;

  • Additional Comments received on Public Discussion Draft – BEPS ACTION 1: ADDRESS THE TAX CHALLENGES OF THE DIGITAL ECONOMY;

  • VOD Public Consultation: Address the Tax Challenges of the Digital Economy (Morning session);

  • VOD Public Consultation: Address the Tax Challenges of the Digital Economy (Afternoon session);

     

• Request for Input Regarding Work on Tax Challenges of the Digital Economy

  • COMPILATION OF COMMENTS RECEIVED IN RESPONSE TO REQUEST FOR INPUT ON TAX CHALLENGES OF THE DIGITAL ECONOMY;

     

     

    ACTION 2

    Neutralise the effects of hybrid mismatch arrangements

• OECD/G20 BASE EROSION AND PROFIT SHIFTING PROJECT – NEUTRALISING THE EFFECTS OF HYBRID MISMATCH ARRANGEMENTS - ACTION 2: 2014 DELIVERABLE (SEPTEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW)

 

• PUBLIC DISCUSSION DRAFT BEPS ACTION 2: NEUTRALISE THE EFFECTS OF HYBRID MISMATCH ARRANGEMENTS (TREATY ISSUES) (MARCH 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

• Comments received on Public Discussion drafts – BEPS ACTION 2: NEUTRALISE THE EFFECTS OF HYBRID MISMATCH ARRANGEMENTS;

• PUBLIC DISCUSSION DRAFT BEPS ACTION 2: NEUTRALISE THE EFFECTS OF HYBRID MISMATCH ARRANGEMENTS (RECOMMENDATIONS FOR DOMESTIC LAWS) (MARCH 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments received on Public Discussion drafts – BEPS ACTION 2: NEUTRALISE THE EFFECTS OF HYBRID MISMATCH ARRANGEMENTS;

     

     

    ACTION 3

    Strengthen CFC rules

 

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 3: STRENGTHENING CFC RULES (APRIL 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);
  

  • Comments received on Public Discussion Draft - BEPS ACTION 3: STRENGTHENING CFC RULES (PART 1)

  • Comments received on Public Discussion Draft - BEPS ACTION 3: STRENGTHENING CFC RULES (PART 2)

     

   

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 3: STRENGTHENING CFC RULES (APRIL 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);
  

  • Comments received on Public Discussion Draft - BEPS ACTION 3: STRENGTHENING CFC RULES (PART 1)

  • Comments received on Public Discussion Draft - BEPS ACTION 3: STRENGTHENING CFC RULES (PART 2)

  
  

   

   

  ACTION 4

  Limit base erosion via interest deductions and other financial payments

 

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 4 - APPROACHES TO ADDRESS BEPS INVOLVING INTEREST IN THE BANKING AND INSURANCE SECTORS (JULY 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 4 - ELEMENTS OF THE DESIGN AND OPERATION OF THE GROUP RATIO RULE (JULY 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 4: INTEREST DEDUCTIONS AND OTHER FINANCIAL PAYMENTS (DECEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments received on Public Discussion Draft – BEPS ACTION 4: INTEREST DEDUCTIONS AND OTHER FINANCIAL PAYMENTS (Part 1);

  • Comments received on Public Discussion Draft – BEPS ACTION 4: INTEREST DEDUCTIONS AND OTHER FINANCIAL PAYMENTS (Part 2);

  • VOD Public Consultation: Interest Deductions and Other Financial Payments (Morning session);

  • VOD Public Consultation: Interest Deductions and Other Financial Payments (Afternoon session);

   

   

   

ACTION 5

Counter harmful tax practices more effectively, taking into account transparency and substance

 

• OECD/G20 BASE EROSION AND PROFIT SHIFTING PROJECT – ACTION 5: AGREEMENT ON MODIFIED NEXUS APPROACH FOR IP REGIMES (FEBRUARY 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• EXPLANATORY PAPER – AGREEMENT ON MODIFIED NEXUS APPROACH FOR IP REGIMES (FEBRUARY 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• OECD/G20 BASE EROSION AND PROFIT SHIFTING PROJECT – COUNTERING HARMFUL TAX PRACTICES MORE EFFECTIVELY, TAKING INTO ACCOUNT TRANSPARENCY AND SUBSTANCE – ACTION 5: 2014 DELIVERABLE (SEPTEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

 

 

 

ACTION 6

Prevent treaty abuse

 

• PUBLIC DISCUSSION DRAFT - TREATY ENTITLEMENT OF NON-CIV FUNDS (MARCH 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);
  • COMMENTS RECEIVED ON PUBLIC DISCUSSION DRAFT – TREATY ENTITLEMENT OF NON-CIV FUNDS (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• PUBLIC DISCUSSION DRAFT – TREATY RESIDENCE OF PENSION FUNDS (FEBRUARY 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);
• COMMENTS RECEIVED ON PUBLIC DISCUSSION DRAFT – TREATY RESIDENCE OF PENSION FUNDS (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• REVISED DISCUSSION DRAFT – BEPS ACTION 6: PREVENT TREATY ABUSE (MAY 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

• COMMENTS RECEIVED ON REVISED DISCUSSION DRAFT – BEPS ACTION 6: PREVENT TREATY ABUSE;

   

• PUBLIC DISCUSSION DRAFT - FOLLOW-UP ON BEPS ACTION 6: PREVENTING TREATY ABUSE (NOVEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments Received on Public Discussion Draft – FOLLOW-UP WORK ON BEPS ACTION 6: PREVENT TREATY ABUSE;

  • VOD Public Consultation: Follow-Up Work on BEPS Action 6 (Morning Session);

  • VOD Public Consultation: Follow-Up Work on BEPS Action 6 (Afternoon session);

     

• OECD/G20 BASE EROSION AND PROFIT SHIFTING PROJECT – PREVENTING THE GRANTING OF TREATY BENEFITS IN INAPPROPRIATE CIRCUMSTANCES – ACTION 6: 2014 DELIVERABLE (SEPTEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

   

• PUBLIC DISCUSSION DRAFT BEPS ACTION 6: PREVENTING THE GRANTING OF TREATY BENEFITS IN INAPPROPRIATE CIRCUMSTANCES (MARCH 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments Received on Public Discussion Draft – BEPS ACTION 6: PREVENTING THE GRANTING OF TREATY BENEFITS IN INAPPROPRIATE CIRCUMSTANCES;

     

     

    ACTION 7

    Prevent the artificial avoidance of PE status

 

• REVISED DISCUSSION DRAFT – BEPS ACTION 7: PREVENTING THE ARTIFICIAL AVOIDANCE OF PE STATUS (MAY 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

• COMMENTS RECEIVED ON REVISED DISCUSSION DRAFT – BEPS ACTION 7: PREVENTING THE ARTIFICIAL AVOIDANCE OF PE STATUS;

• PUBLIC DISCUSSION DRAFT – BEPS ACTION 7: PREVENTING THE ARTIFICIAL AVOIDANCE OF PE STATUS (OCTOBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);
  

  • Comments received on Public Discussion Draft – BEPS ACTION 7: PREVENT THE ARTIFICIAL AVOIDANCE OF PE STATUS;

  • VOD Public Consultation: Prevent the Artificial Avoidance of PE Status (Morning session);

  • VOD Public Consultation: Prevent the Artificial Avoidance of PE Status (Afternoon session);

  
  

   

  ACTION 8

  Assure that transfer pricing outcomes are in line with value creation

  (Intangibles)

 

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 8-10: REVISED GUIDANCE ON PROFIT SPLITS (JULY 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• DOCUMENT FOR PUBLIC REVIEW: CONFIRMING AMENDMENTS TO CHAPTER IX OF THE TRANSFER PRICING GUIDELINES (JULY 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• PUBLIC DISCUSSION DRAFT – BEPS ACTION 8: HARD-TO-VALUE INTANGIBLES (JUNE 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

• Comments received on Public Discussion Draft – BEPS ACTION 8: HARD-TO-VALUE INTANGIBLES;

• VOD Public Consultation: Hard-to-Value Intangibles;

 

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 8: REVISIONS TO CHAPTER VIII OF THE TRANSFER PRICING GUIDELINES ON COST CONTRIBUTION ARRANGEMENTS (CCAs) (APRIL 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

• Comments received on Public Discussion Draft – BEPS ACTION 8: REVISIONS TO CHAPTER VIII OF THE TRANSFER PRICING GUIDELINES ON COST CONTRIBUTION ARRANGEMENTS (CCAs);

• VOD Public Consultation: Cost Contribution Arrangements;

   

• PUBLIC DISCUSSION DRAFT - BEPS ACTIONS 8, 9, 10: DISCUSSION DRAFT ON REVISIONS TO CHAPTER I OF THE TRANSFER PRICING GUIDELINES (INCLUDING RISK, RECHARACTERISATION, AND SPECIAL MEASURES (DECEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments received on Public Discussion Draft – BEPS ACTIONS 8, 9 AND 10: REVISIONS TO CHAPTER I OF THE TRANSFER PRICING GUIDELINES (INCLUDING RISK, RECHARACTERISATION, AND SPECIAL MEASURES) (Part 1);

  • Comments received on Public Discussion Draft – BEPS ACTIONS 8, 9 AND 10: REVISIONS TO CHAPTER I OF THE TRANSFER PRICING GUIDELINES (INCLUDING RISK, RECHARACTERISATION, AND SPECIAL MEASURES) (Part 2);

  • VOD Public Consultation: Prevent the status of revisions to chapter I and chapter VI of the Transfer Pricing Guidelines;

     

     

• OECD/G20 BASE EROSION AND PROFIT SHIFTING PROJECT – GUIDANCE ON TRANSFER PRICING ASPECTS OF INTANGIBLES – ACTION 8: 2014 DELIVERABLE (SEPTEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

   

• REVISED DISCUSSION DRAFT ON TRANSFER PRICING ASPECTS OF INTANGIBLES (JULY 2013) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW).

  • OECD publishes comments received on the Revised Discussion Draft on Transfer Pricing Aspects of Intangibles;

     

     

    ACTION 9

    Assure that transfer pricing outcomes are in line with value creation

    (Risks and capital)

 

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 8-10: REVISED GUIDANCE ON PROFIT SPLITS (JULY 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• DOCUMENT FOR PUBLIC REVIEW: CONFIRMING AMENDMENTS TO CHAPTER IX OF THE TRANSFER PRICING GUIDELINES (JULY 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• PUBLIC DISCUSSION DRAFT - BEPS ACTIONS 8, 9, 10: DISCUSSION DRAFT ON REVISIONS TO CHAPTER I OF THE TRANSFER PRICING GUIDELINES (INCLUDING RISK, RECHARACTERISATION, AND SPECIAL MEASURES (DECEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

• Comments received on Public Discussion Draft – BEPS ACTIONS 8, 9 AND 10: REVISIONS TO CHAPTER I OF THE TRANSFER PRICING GUIDELINES (INCLUDING RISK, RECHARACTERISATION, AND SPECIAL MEASURES) (Part 1);

• Comments received on Public Discussion Draft – BEPS ACTIONS 8, 9 AND 10: REVISIONS TO CHAPTER I OF THE TRANSFER PRICING GUIDELINES (INCLUDING RISK, RECHARACTERISATION, AND SPECIAL MEASURES) (Part 2);

   

   

  ACTION 10

  Assure that transfer pricing outcomes are in line with value creation

  (Other high-risk transactions)

 

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 8-10: REVISED GUIDANCE ON PROFIT SPLITS (JULY 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• DOCUMENT FOR PUBLIC REVIEW: CONFIRMING AMENDMENTS TO CHAPTER IX OF THE TRANSFER PRICING GUIDELINES (JULY 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

   

• PUBLIC DISCUSSION DRAFT - BEPS ACTIONS 8, 9, 10: DISCUSSION DRAFT ON REVISIONS TO CHAPTER I OF THE TRANSFER PRICING GUIDELINES (INCLUDING RISK, RECHARACTERISATION, AND SPECIAL MEASURES) (DECEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments received on Public Dicussion Draft – BEPS ACTIONS 8, 9 AND 10: REVISIONS TO CHAPTER I OF THE TRANSFER PRICING GUIDELINES (INCLUDING RISK, RECHARACTERISATION, AND SPECIAL MEASURES) (Part 1);

  • Comments received on Public Discussion Draft – BEPS ACTIONS 8, 9 AND 10: REVISIONS TO CHAPTER I OF THE TRANSFER PRICING GUIDELINES (INCLUDING RISK, RECHARACTERISATION, AND SPECIAL MEASURES) (Part 2);

     

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 10: DISCUSSION DRAFT ON THE TRANSFER PRICING ASPECTS OF CROSS-BORDER COMMODITY TRANSACTIONS (DECEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments received on Public Discussion Draft – BEPS ACTION 10: TRANSFER PRICING ASPECTS OF CROSSBORDER COMMODITY TRANSACTIONS;

     

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 10: DISCUSSION DRAFT ON THE USE OF PROFIT SPLITS IN THE CONTEXT OF GLOBAL VALUE CHAINS (DECEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments received on Public Discussion Draft – BEPS ACTION 10: USE OF PROFIT SPLITS IN THE CONTEXT OF GLOBAL VALUE CHAINS;

     

• PUBLIC DISCUSSION DRAFT – BEPS ACTION 10: PROPOSED MODIFICATIONS TO CHAPTER VII OF THE TRANSFER PRICING GUIDELINES RELATING TO LOW VALUE-ADDING INTRA-GROUP SERVICES (NOVEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments received on Public Discussion Draft – BEPS ACTION 10: PROPOSED MODIFICATIONS TO CHAPTER VII OF THE TRANSFER PRICING GUIDELINES RELATING TO LOW VALUE-ADDING INTRA-GROUP SERVICES;

     

     

    ACTION 11

    Establish methodologies to collect and analyse data on BEPS and the actions to address it

• PUBLIC DISCUSSION DRAFT – BEPS ACTION 11: IMPROVING THE ANALYSIS OF BEPS (APRIL 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW)
  

  • Comments received on Public Discussion Draft – BEPS ACTION 11: IMPROVING THE ANALYSIS OF BEPS

   
  

• REQUEST FOR INPUT – BEPS ACTION 11:  ESTABLISH METHODOLOGIES TO COLLECT AND ANALYSE DATA ON BEPS AND THE ACTIONS TO ADDRESS IT (AUGUST 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments Received on Public Discussion Draft – BEPS ACTION 11: Establish methodologies to collect and analyse data on BEPS and the actions to address it;

     

     

    ACTION 12

    Require taxpayers to disclose their aggressive tax planning arrangements

     

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 12: MANDATORY DISCLOSURE RULES (MARCH 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

   

   

  ACTION 13

  Re-examine transfer pricing documentation

 

• DOCUMENT FOR PUBLIC REVIEW: CONFIRMING AMENDMENTS TO CHAPTER IX OF THE TRANSFER PRICING GUIDELINES (JULY 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

    

• Guidance on the implementation of Country-by-Country Reporting (As released by the OECD on June 29, 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

 

• MULTILATERAL COMPETENT AUTHORITY AGREEMENT ON THE EXCHANGE OF COUNTRY-BY-COUNTRY REPORTS (As signed by 31 Jurisdictions on January 27, 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

   

   

• ACTION 13: COUNTRY-BY-COUNTRY REPORTING IMPLEMENTATION PACKAGE (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

   

   

• OECD/G20 BASE EROSION AND PROFIT SHIFTING PROJECT – ACTION 13: GUIDANCE ON THE IMPLEMENTATION OF TRANSFER PRICING DOCUMENTATION AND COUNTRY-BY-COUNTRY REPORTING (FEBRUARY 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

   

• OECD/G20 BASE EROSION AND PROFIT SHIFTING PROJECT – GUIDANCE ON TRANSFER PRICING DOCUMENTATION AND COUNTRY-BY-COUNTRY REPORTING – ACTION 13: 2014 DELIVERABLE (SEPTEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

   

• DISCUSSION DRAFT ON TRANSFER PRICING DOCUMENTATION AND COUNTRY BY COUNTRY REPORTING (JANUARY 2014) (YOU WILL BE FOWARDED TO THE OECD WEBSITE, WHICH WILL OPEN IN A NEW WINDOW);

  • Public Comments received – Discussion Draft on Transfer Pricing Documentation and CbC Reporting (VOLUME I - Letters A to C);

  • Public Comments received – Discussion Draft on Transfer Pricing Documentation and CbC Reporting (VOLUME II - Letters D to J);

  • Public Comments received – Discussion Draft on Transfer Pricing Documentation and CbC Reporting (VOLUME III - Letters K to R);

  • Public Comments received – Discussion Draft on Transfer Pricing Documentation and CbC Reporting (VOLUME IV - Letters S to Z);

     

• MEMORANDUM ON TRANSFER PRICING DOCUMENTATION AND COUNTRY BY COUNTRY REPORTING (OCTOBER 2013) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

   

• WHITE PAPER ON TRANSFER PRICING DOCUMENTATION (JULY 2013) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

  • OECD publishes comments received on the White Paper on Transfer Pricing Documentation

     

     

    ACTION 14

    Make dispute resolution mechanisms more effective

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 14: MAKE DISPUTE RESOLUTION MECHANISMS MORE EFFECTIVE (DECEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments Received on Public Discussion Draft – BEPS ACTION 14: MAKE DISPUTE RESOLUTION MECHANISMS MORE EFFECTIVE;

  • VOD Public Consultation: Make Dispute Resolution Mechanisms More Effective (Morning session);

     

     

    ACTION 15

    Develop a multilateral instrument

     

• PUBLIC DISCUSSION DRAFT - BEPS ACTION 15 DEVELOPMENT OF A MULTILATERAL INSTRUMENT TO IMPLEMENT THE TAX TREATY RELATED BEPS MEASURES (MAY 2016) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

  • Comments Received on Public Discussion Draft – BEPS ACTION 15: DEVELOPMENT OF A MULTILATERAL INSTRUMENT TO IMPLEMENT THE TAX TREATY RELATED BEPS MEASURES;
  • VOD Public Consultation from July 7, 2016 (Morning session);
  • VOD Public Consultation from July 7, 2016 (Afternoon session);

 

• OECD/G20 BASE EROSION AND PROFIT SHIFTING PROJECT – ACTION 15: A MANDATE FOR DEVELOPMENT OF A MULTILATERAL INSTRUMENT ON TAX TREATY MEASURES TO TACKLE BEPS (FEBRUARY 2015) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

   

• OECD/G20 BASE EROSION AND PROFIT SHIFTING PROJECT – DEVELOPING A MULTILATERAL INSTRUMENT TO MODIFY BILATERAL TAX TREATIES – ACTION 15: 2014 DELIVERABLE (SEPTEMBER 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECDiLIBRARY, WHICH WILL OPEN IN A NEW WINDOW);

   

   

  OTHER BEPS RELATED DOCUMENTS

• PART 1 OF A REPORT TO G20 DEVELOPMENT WORKING GROUP ON THE IMPACT OF BEPS IN LOW INCOME COUNTRIES (JULY 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

   

• PART 2 OF A REPORT TO G20 DEVELOPMENT WORKING GROUP ON THE IMPACT OF BEPS IN LOW INCOME COUNTRIES (AUGUST 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

   

• GLOBAL FORUM ON TRANSPARENCY AND EXCHANGE OF INFORMATION FOR TAX PURPOSES – AUTOMATIC EXCHANGE OF INFORMATION: A ROADMAP FOR DEVELOPING COUNTRY PARTICIPATION – FINAL REPORT TO THE G20 DEVELOPMENT WORKING GROUP (AUGUST 2014) (YOU WILL BE FORWARDED TO THE WEBSITE OF THE OECD, WHICH WILL OPEN IN A NEW WINDOW);

   

   

   

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