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In contrast, the OECD has spent decades developing intellectual property as a legal and a GAAP accounting concept. [59] Ireland, who has some of the most advanced IP-based BEPS tools in the world, [60] and have the first OECD-approved IP-box, [61] has been a supporter of the OECD BEPS project (see Feargal O'Rourke quote). [62]
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, sometime abbreviated BEPS multilateral instrument, is a multilateral convention of the Organisation for Economic Co-operation and Development to combat tax avoidance by multinational enterprises (MNEs) through prevention of Base Erosion and Profit Shifting (BEPS).
So, best I can tell, neither the OECD's base erosion and profit shifting work nor the U.S. [TCJA] tax reform, will end the ability of major U.S. companies to reduce their overall tax burden by aggressively shifting profits offshore (and paying between 0 [and] 3 percent on their offshore profits and then being taxed at the GILTI 10.5 percent ...
On 8 October 2021, the EU members Republic of Ireland, Hungary, and Estonia agreed to the OECD plan under the condition that the 15% tax rate will not be raised. [16] The 8 October 2021 statement is called Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy . 137 countries in total ...
In October 2015, the OECD released the final reports on the Base Erosion and Profit Shifting (BEPS) project. Action 7 was targeted at Preventing the Artificial Avoidance of Permanent Establishment Status and proposes a large number of changes that are set to be included in the next version of the OECD Model Tax Convention.
The OECD Model Tax Convention provides the legal framework for governments to have their fair share of taxes, and for enterprises to avoid double taxation on their profits. The arm's length standard is instrumental to determine how much of the profits should be attributed to one entity and, consequently, the extent of a country's tax claim on ...
The Transfer Pricing Guidelines serve as a template for the profit allocation of inter-company transactions to countries. The latest version, of July 2017, incorporates the approved Actions developed under the Base Erosion and Profit Shifting (BEPS) project initiated by the G20. [citation needed] Pillar 1
According to the OECD Council decision each adhering country has to set up a National Contact Point (NCP), an entity responsible for the promotion of the Guidelines on a national level. It handles all enquiries and matters related to the Guidelines in that country, including investigating complaints (referred to as "specific instances" [ 8 ...