OECD/G20 Base Erosion and Profit Shifting Project Developing a Multilateral Instrument to Modify Bilateral Tax Treaties, Action 15 - 2015 Final Report


Book Description

Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 15.




Developing a Multilateral Instrument to Modify Bilateral Tax Treaties


Book Description

Drawing on the expertise of public international law and tax experts, this report explores the technical feasibility to develop a multilateral instrument to modify tax treaties so as to efficiently implement the tax treaty-related BEPS measures. The report concludes that such an instrument is desirable and feasible and that negotiations for the multilateral instrument should be convened quickly. Based on this analysis, a mandate has been developed for an ad-hoc group, open to the participation of all countries on an equal footing, to develop the multilateral instrument and open it for signature in 2016.




Developing a Multilateral Instrument to Modify Bilateral Tax Treaties


Book Description

This report identifies the issues arising from the development of a multilateral instrument that modifies bilateral tax treaties. Without a mechanism for swift implementation, changes to model tax conventions only widen the gap between the content of these models and the content of actual tax treaties. Developing such a mechanism is necessary not only to tackle base erosion and profit shifting, but also to ensure the sustainability of the consensual framework to eliminate double taxation. This is an innovative approach with no exact precedent in the tax world, but precedents for modifying bilateral treaties with a multilateral instrument exist in various other areas of public international law. Drawing on the knowledge of experts in public international law and taxation, the Report concludes that a multilateral instrument is desirable and feasible, and that negotiations for such an instrument should be convened quickly.




OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, New Zealand (Stage 1) Inclusive Framework on BEPS: Action 14


Book Description

Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to ...




OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Bahrain (Stage 2) Inclusive Framework on BEPS: Action 14


Book Description

Under BEPS Action 14, members of the OECD/G20 Inclusive Framework on BEPS have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The BEPS Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' Stage 1 peer review report. This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by Bahrain.




OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 1) Inclusive Framework on BEPS: Action 14


Book Description

Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to ...







OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Denmark (Stage 1) Inclusive Framework on BEPS: Action 14


Book Description

This report reflects the outcome of the stage 1 peer review of the implementation of the Action 14 Minimum Standard by the Czech Republic, which is accompanied by a document addressing the implementation of best practices which can be accessed on the OECD website.




OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Australia (Stage 1) Inclusive Framework on BEPS: Action 14


Book Description

Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to ...