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Ireland's capital allowances for intangibles scheme was the BEPS structure to secure it as an ultra-low tax (i.e. 0-3% in perpuity) location for U.S. multinationals, that is in full compliance with all OECD guidelines, and the OECD BEPS project. [63] However, the U.S. and EU's new tax regimes deliberately "override" these IP-based BEPS tools.
In December 2016, Cobham highlighted one of the key anti-BEPS Actions, full public country-by-country reporting ("CbCr"), had been dropped due to lobbying by the U.S. multinationals. [69] Country-by-country reporting is the only way to observe the level of BEPS activity and OECD compliance in any country conclusively.
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).
The Green Jersey thus gives a perpetual BEPS tool, like the double Irish, but at a much greater scale than the double Irish, as the full BEPS effect is capitalised on day one. Experts expect the U.S. Tax Cuts and Jobs Act of 2017 ("TCJA") GILTI-regime to neutralise some Irish BEPS tools, including the single malt and the double Irish. [140]
The Organisation for Economic Co-operation and Development (OECD; French: Organisation de coopération et de développement économiques, OCDE) is an intergovernmental organization with 38 member countries, [1] [4] founded in 1961 to stimulate economic progress and world trade.
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] The OECD’s 2015 final BEPS reports called for country-by-country ...
The key difference in the Irish KDB to those of other European countries is its compliance with the OECD's Base Erosion and Profit Shifting (BEPS) [14] programme, Ireland's is the first patent-box type system to offer compliance in this area. Companies availing of the current R&D tax credit should be aware of the KDB and the potential for them ...
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.