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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 UK Government has pushed the initiative led by the Organisation for Economic Co-operation and Development (OECD) on base erosion and profit shifting. [90] In the 2015 Autumn Statement, Chancellor George Osborne announced that £800m would be spent on tackling tax avoidance in order to recover £5 billion a year by 2019–20.
However, aggressive intragroup pricing – especially for debt and intangibles – has played a major role in corporate tax avoidance, [18] and it was one of the issues identified when the OECD released its base erosion and profit shifting (BEPS) action plan in 2013. [19]