Download or read book OECD G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements Action 2 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 2.

Download or read book OECD G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements Action 2 Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2017-07-27 with total page 104 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).

Download or read book OECD G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements written by OECD and published by OECD Publishing. This book was released on 2014-09-16 with total page 103 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report, produced by the OECD/G20 Project on Base Erosion and Profit Shifting sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements.

Download or read book Neutralising the Effects of Hybrid Mismatch Arrangements written by Oecd and published by OCDE. This book was released on 2014-09-16 with total page 99 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements. Once translated into domestic law, the recommendations in Part 1 of the report will neutralise the effect of cross-border hybrid mismatch arrangements that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part 1 of the report will be supplemented by a commentary, which will explain the recommended rules and illustrate their application with practical examples. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases. Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.

Download or read book Neutralising the Effects of Branch Mismatch Arrangements Action 2 written by Organization for Economic Development and Cooperation and published by Organization for Economic Co-Operation & Development. This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report). Branch mismatches arise where the ordinary rules for allocating income and expenditure between the branch and head office result in a portion of the net income of the taxpayer escaping the charge to taxation in both the branch and residence jurisdiction. Unlike hybrid mismatches, which result from conflicts in the legal treatment of entities or instruments, branch mismatches are the result of differences in the way the branch and head office account for a payment made by or to the branch. The 2017 report identifies five basic types of branch mismatch arrangements that give rise to one of three types of mismatches: deduction / no inclusion (D/NI) outcomes, double deduction (DD) outcomes, and indirect deduction / no inclusion (indirect D/NI) outcomes. This report includes specific recommendations for improvements to domestic law intended to reduce the frequency of branch mismatches as well as targeted branch mismatch rules which adjust the tax consequences in either the residence or branch jurisdiction in order to neutralise the hybrid mismatch without disturbing any of the other tax, commercial or regulatory outcomes. The annexes of the report summarise the recommendations and set out a number of examples illustrating the intended operation of the recommended rules.

Download or read book Limiting Base Erosion written by Erik Pinetz and published by Linde Verlag GmbH. This book was released on 2017-08-30 with total page 568 pages. Available in PDF, EPUB and Kindle. Book excerpt: Limiting base erosion from different viewpoints Hybrid mismatch arrangements, CFC rules, transfer pricing rules: “Limiting Base Erosion”, the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices still has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to the OECD Member countries that have to properly implement the OECD recommendations in their domestic laws as well as in their tax treaty practice. In this respect, a comprehensive analysis in the literature of all the issues related to base erosion proves to be of the utmost importance in order to provide practical guidance to the Member countries during that the process of implementation. This book deals especially with four key areas of interest:Limiting base erosion by neutralizing the effects of hybrid mismatch arrangementsLimiting base erosion by strengthening CFC rulesMeasures against base erosion via interest deductions and other financial paymentsLimiting base erosion by improving transfer pricing rules.On that basis, 27 concrete topics were chosen in order to address the four key areas of interest from different viewpoints. Base erosion and the challenges they present: read more in “Limiting Base Erosion”.

Download or read book Action Plan on Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-07-19 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

Download or read book OECD G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports written by OECD and published by OECD Publishing. This book was released on 2016-08-26 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting is a key priority of governments around the globe. This Explanatory Statement offers an overview of the BEPS Project and outcomes.

Download or read book OECD G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective MAP Peer Review Report Turkey Stage 2 Inclusive Framework on BEPS Action 14 written by OECD and published by OECD Publishing. This book was released on 2021-05-25 with total page 93 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Turkey.

Download or read book OECD G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective MAP Peer Review Report Malta Stage 2 Inclusive Framework on BEPS Action 14 written by OECD and published by OECD Publishing. This book was released on 2021-04-15 with total page 92 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard of Malta, which is accompanied by a document addressing the implementation of best practices.

Download or read book OECD G20 Base Erosion and Profit Shifting Project Making Dispute Resolution Mechanisms More Effective Action 14 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 50 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 14.

Download or read book Hybrid Financial Instruments Double Non Taxation and Linking Rules written by Félix Daniel Martínez Laguna and published by Kluwer Law International B.V.. This book was released on 2019-06-12 with total page 685 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.

Download or read book OECD G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective MAP Peer Review Report Argentina Stage 2 Inclusive Framework on BEPS Action 14 written by OECD and published by OECD Publishing. This book was released on 2021-07-26 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Argentina.

Download or read book OECD G20 Base Erosion and Profit Shifting Project Mandatory Disclosure Rules Action 12 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 102 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 12.

Download or read book OECD G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective MAP Peer Review Report New Zealand Stage 2 Inclusive Framework on BEPS Action 14 written by OECD and published by OECD Publishing. This book was released on 2021-04-15 with total page 93 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard of New Zealand, which is accompanied by a document addressing the implementation of best practices.

Download or read book OECD G20 Base Erosion and Profit Shifting Project Countering Harmful Tax Practices More Effectively Taking into Account Transparency and Substance Action 5 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 85 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 5.

Download or read book Addressing hybrid mismatch arrangements written by Policy and Stratgey, Inland Revenue, New Zealand and published by Policy and Strategy, Inland Revenue, New Zealand. This book was released on 2016-09-06 with total page 87 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid mistmatch arrangements are one of the main base erosion and profit shifting (BEPS) strategies used by some large international companies to pay little or no tax anywhere in the world. The OECD developed recommendations for anti-hybrid measures in its 15 point Base Erosion and Profit Shifting (BEPS) Action Plan. This Government discussion document seeks comments on how the OECD recommendations could be implemented in New Zealand. Part I of the document describes the problem of hybrid mismatch arrangements, the case for responding to the problem, and a summary of the OECD recommendations. Part II of the document explains the OECD recommendations in greater depth and discusses how they could be incorporated into New Zealand law.