OECD Working Party No. 6 releases a discussion draft on the Transfer Pricing Aspects of Intangibles

The Global Forum Secretariat enters into a Memorandum of Understanding with the United Arab Emirates, confirming UAE’s commitment to the Global Forum’s work on transparency and exchange of information.

Furthering its efforts to strengthen international tax co-operation, the OECD has issued two new reports on automatic exchange and tax confidentiality. The report on automatic exchange of information describes what it is, how it works, where it stands and what challenges remain. The report on confidentiality of information exchanged examines all aspects of ensuring the protection of information exchanged for tax purposes.

The OECD Committee on Fiscal Affairs invites public comments on a revised discussion draft on the meaning of “beneficial owner”, a term that is used in Articles 10, 11 and 12 of the OECD Model Tax Convention.

The OECD Committee on Fiscal Affairs invites public comments on a revised discussion draft on the definition of “permanent establishment” that is included in Article 5 of the OECD Model Tax Convention.

The OECD Committee on Fiscal Affairs invites public comments on a revised discussion draft on tax treaty issues related to emissions permits/credits, which addresses the application of the provisions of the OECD Model Tax Convention to the cross-border granting and trading of emissions permits and credits.

On 6 June 2012, the OECD released an invitation to comment on a discussion draft on the Transfer Pricing Aspects of Intangibles. The comments received in response to this invitation have been published. This edition replaces the previous edition released on 28 September 2012.

On 6 June 2012, the OECD released an invitation to comment on a discussion draft on the revision of the Safe Harbours Section in Chapter IV of the Transfer Pricing Guidelines. The comments received in response to this invitation have been published. This edition replaces the previous edition released on 28 September 2012.

On 6 June 2012, the OECD released an invitation to comment on a discussion draft on timing issues relating to transfer pricing. The comments received in response to this invitation have been published. This edition replaces the previous edition released on 28 September 2012.

Invitation to attend the OECD-BIAC public briefing session on TRACE and FATCA

The amount of cross border portfolio investment exceeds 35 trillion USD. To encourage growth and cross-border investment more than 3000 tax treaties around the world based on the OECD Model reduce source taxation on a reciprocal basis.

On 19 October 2012, the OECD Committee on Fiscal Affairs released for public comment revised proposals concerning the meaning of “beneficial owner” in Articles 10, 11 and 12 of the OECD Model Tax Convention. The OECD has now published the comments received on this revised discussion draft.

On 19 October 2012, the OECD Committee on Fiscal Affairs released for public comment a revised discussion draft on tax treaty issues related to emissions permits and credits. The OECD has now published the comments received on this revised discussion draft.

On 19 October 2012, the OECD Committee on Fiscal Affairs released for public comment a revised discussion draft on the definition of “permanent establishment” (Article 5) of the OECD Model Tax Convention. The OECD has now published the comments received on this revised discussion draft.

The OECD has released a study to help all countries understand and address the risks of sales suppression software. It describes some of the most common electronic sales suppression techniques and shows how these methods can be detected by tax auditors. The report also considers the approaches already adopted by countries in combating this risk and highlights a number of best practices.

New data show that across OECD countries the average tax and social security burden on employment incomes increased by 0.1 of a percentage point to 35.6 per cent in 2012. It increased in 19 out of 34 countries, fell in 14, and remained unchanged in 1.

The Steering Committee of the OECD Global Forum on Transfer Pricing publishes a Draft Handbook on Transfer Pricing Risk Assessment. This Handbook is intended to provide practical guidance to tax administrations in both OECD and non-OECD economies regarding the process of conducting transfer pricing risk assessments. Interested parties are invited to provide comments by 13 September 2013.

The OECD Council has approved the revision of Section E on safe harbours in Chapter IV of the Transfer Pricing Guidelines. New guidance provides opportunities for countries to relieve some compliance burdens and to provide greater certainty for cases involving smaller taxpayers or less complex transactions. It encourages the use of bilateral or multilateral safe harbours and provides sample MOUs to establish bilateral safe harbours.

As a further sign of international efforts to crack down on tax offenders, 12 more countries have signed, or committed to sign, the OECD’s Multilateral Convention on Mutual Administrative Assistance in Tax Matters. In addition, another 6 countries have ratified the Convention.

OECD governments have committed to stepping up their efforts to tackle base erosion and profit shifting (BEPS) by endorsing the OECD's BEPS Declaration at the Organisation’s annual Ministerial Meeting in Paris.

Mr. Angel Gurría, Secretary-General of the OECD, attended the Working Lunch of the G8 Summit and delivered the OECD report “A Step Change in Tax Transparency - Delivering a standardised, secure and cost effective model of bilateral automatic exchange for the multilateral context” and remarks on Trade, Tax, Transparency which are the key priorities of the UK G8 Presidency for the Summit.

National tax laws have not kept pace with the globalisation of corporations and the digital economy, leaving gaps that can be exploited by multi-national corporations to artificially reduce their taxes.

The OECD released for public comment a Revised Discussion Draft on Transfer Pricing Aspects of Intangibles. The Revised Discussion Draft updates and expands an earlier discussion draft released in June 2012 to reflect comments received and further discussions of country delegates to Working Party No. 6 of the Committee on Fiscal Affairs. Comments of interested persons are requested by 1 October 2013.

OECD Secretary-General Gurría today presented to G20 Leaders ground-breaking proposals to tackle tax evasion and avoidance by both companies and individuals. The proposals establish automatic exchange of information for tax purposes as the new international standard for tax co-operation and set out the Action Plan on Base Erosion and Profit Shifting (BEPS), which was first presented to G20 Finance Ministers in Moscow in July 2013.

"Tax Policy Landscape Five Years after the Crisis" discusses how tax policies have responded to fiscal and macroeconomic developments over the past five years and these longer-term structural economic developments on. "Tax Reform in the People's Republic of China" compares the tax system in China with the tax system in OECD countries and the tax reforms China and OECD countries have implemented in the past.

On 30 April 2013, the OECD invited comments from interested parties on the new Draft Handbook on Transfer Pricing Risk Assessment, produced by the Steering Committee of the OECD Global Forum on Transfer Pricing. The OECD now publishes the comments received.

Strong competition is an optimizer for our economies. First of all, it is the best catalyst to increase our productivity. This is because a strong competition framework generates the right incentives to attract the most efficient firms into our markets.

A public consultation will be held at the OECD Conference Centre on 12-13 November 2013. The public consultation is open to all interested persons and will be attended by country delegates to Working Party No. 6 of the OECD Committee on Fiscal Affairs. Persons interested in attending must register in advance through the OECD website.

On 30 July 2013, the OECD invited comments from interested parties on the Revised Discussion Draft on Transfer Pricing Aspects of Intangibles. The comments received in response to this invitation have been published.

This report looks at the issue of tax crime in the fisheries sector, including frauds over taxes on profit and earnings, customs duties, VAT and social security, with examples from real cases.

OECD Secretary-General Angel Gurria welcomed today Liechtenstein’s announcement of plans to sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters and take further steps to increase transparency and international co-operation.

The OECD invites public comments on a discussion draft that includes proposed changes to the OECD Model Tax Convention dealing with the operation of ships and aircraft in international traffic.

The OECD Committee on Fiscal Affairs invites public comments and input on questions related to the tax challenges of the digital economy. The Committee invites interested parties to send their comments in response to this request for input before 22 December 2013.

Tax revenues continue bouncing back from the low levels reported in almost all countries during 2008 and 2009, at the height of the global economic crisis, according to new OECD data in the annual Revenue Statistics publication. The average tax revenue to GDP ratio in OECD countries was 34.6% in 2012, compared with 34.1% in 2011 and 33.8% in 2010.

Tax revenues in Latin American countries continue to rise but are lower as a proportion of their national incomes than in most OECD countries. Revenue Statistics in Latin America 2012 shows that Argentina and Brazil have the highest tax revenue to GDP ratio, while Guatemala and Dominican Republic stand at the lower end.

Interested parties are invited to comment on this paper prepared by the OECD in the context of revision to Chapter V of the Transfer Pricing Guidelines.

On 15 November 2013, the OECD Committee on Fiscal Affairs (CFA) invited public comments on a discussion draft on changes to the provisions of the OECD Model Tax Convention dealing with the operation of ships and aircraft in international traffic. The OECD has now published the comments received on that discussion draft.

A revision of the timetable for planned stakeholders’ input is now available online with the dates when discussion drafts will be published and public consultations held in relation to the September 2014 BEPS outputs.

This paper sets out four possible approaches to addressing the concerns over the lack of data on transfer pricing comparables expressed by developing countries.

Public comments are invited on a discussion draft that includes the proposals produced with respect to Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan.

Public comments are invited on discussion drafts that include the proposals produced with respect to Action 2 (Hybrid Mismatch Arrangements) of the BEPS Action Plan.

Public comments are invited on a discussion draft that includes the proposals produced with respect to Action 1 (Tax Challenges of the Digital Economy) of the BEPS Action Plan.

The OECD publishes comments received from interested parties on the discussion draft on Action 6 (Prevent Treaty Abuse) of the BEPS Action Plan.

Personal income tax has risen in 25 out of 34 OECD countries over the past three years, as countries reduce the value of tax-free allowances and tax credits and subject higher proportions of earnings to tax, according to new data in the annual Taxing Wages publication.

The governments of 86 countries have taken a key step towards preventing value added tax from weighing on trade while also safeguarding state revenues by endorsing the first internationally agreed framework for applying national VAT rules to cross-border transactions.

Tax for development: why better public services matter

OECD publishes comments received on Action 2 discussions drafts (Neutralise the Effects of Hybrid Mismatch Arrangements)

Company cars form a large proportion of the car fleet in many OECD countries and are also influential in determining the composition of the wider vehicle fleet. When employees provided with a company car use that car for personal purposes, personal income tax rules value the benefit in a number of different ways.

Diesel and gasoline account for around 95% of energy used for road transport in the OECD and for the largest share of revenue from taxes on energy. In 33 out of 34 OECD countries, diesel fuel is taxed at lower rates than gasoline both in terms of energy and carbon content.

Taking an important step towards greater transparency and putting an end to banking secrecy in tax matters, the OECD today released the full version of a new global standard for the exchange of information between jurisdictions.