Action Plan on Base Erosion and Profit Shifting

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264202714
Total Pages : 44 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis Action Plan on Base Erosion and Profit Shifting by : OECD

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.

Action Plan on Base Erosion and Profit Shifting

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Author :
Publisher : OECD Publishing
ISBN 13 : 9789264202702
Total Pages : 0 pages
Book Rating : 4.2/5 (27 download)

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Book Synopsis Action Plan on Base Erosion and Profit Shifting by : OECD

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 2013-08-07 with total page 0 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.

Addressing Base Erosion and Profit Shifting

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264192743
Total Pages : 91 pages
Book Rating : 4.2/5 (641 download)

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Book Synopsis Addressing Base Erosion and Profit Shifting by : OECD

Download or read book Addressing Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-02-12 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.

OECD/G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264263438
Total Pages : 20 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports by : OECD

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 20 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.

OECD/G20 Base Erosion and Profit Shifting Project Mandatory Disclosure Rules, Action 12 - 2015 Final Report

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241442
Total Pages : 100 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Mandatory Disclosure Rules, Action 12 - 2015 Final Report by : OECD

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 100 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.

OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports

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Author :
Publisher : Org. for Economic Cooperation & Development
ISBN 13 : 9789264241237
Total Pages : 186 pages
Book Rating : 4.2/5 (412 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Aligning Transfer Pricing Outcomes with Value Creation, Actions 8-10 - 2015 Final Reports written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2015-10-19 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt: The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.

OECD/G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241485
Total Pages : 72 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Transfer Pricing Documentation and Country-by-Country Reporting, Action 13 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 72 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 13.

OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241159
Total Pages : 72 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Designing Effective Controlled Foreign Company Rules, Action 3 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 72 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 3.

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241132
Total Pages : 456 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report by : OECD

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 456 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.

Global Challenges in Public Finance and International Relations

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Author :
Publisher : IGI Global
ISBN 13 : 1522575650
Total Pages : 304 pages
Book Rating : 4.5/5 (225 download)

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Book Synopsis Global Challenges in Public Finance and International Relations by : ?ahin Duran, Deniz

Download or read book Global Challenges in Public Finance and International Relations written by ?ahin Duran, Deniz and published by IGI Global. This book was released on 2019-03-29 with total page 304 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although the concept of international public goods has been established, new international public needs arise by the day. For example, while there are many taxation problems and debates that have not yet been resolved internationally, many new tax-related problems like international transfer pricing, taxation of virtual profits, and taxation of electronic commerce are being added. These issues require studies that will discuss a new agenda and propose solutions for these dilemmas and problems. Global Challenges in Public Finance and International Relations provides an innovative and systematic examination of the present international financial events and institutions, international financial relations, and fiscal difficulties and dilemmas in order to discuss solutions for potential problems in the postmodern world. Highlighting topics such as international aid, public debt, and corporate governance, this publication is designed for executives, academicians, researchers, and students of public finance.

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

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241191
Total Pages : 82 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis 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 by : OECD

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 82 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.

Countering Harmful Tax Practices More Effectively, Taking Into Account Transparency and Substance, Action 5 - 2015 Final Report

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Author :
Publisher : OCDE
ISBN 13 : 9789264241183
Total Pages : 80 pages
Book Rating : 4.2/5 (411 download)

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Book Synopsis Countering Harmful Tax Practices More Effectively, Taking Into Account Transparency and Substance, Action 5 - 2015 Final Report by : OCDE,

Download or read book Countering Harmful Tax Practices More Effectively, Taking Into Account Transparency and Substance, Action 5 - 2015 Final Report written by OCDE, and published by OCDE. This book was released on 2015-10-12 with total page 80 pages. Available in PDF, EPUB and Kindle. Book excerpt: Preferential regimes continue to be a key pressure area. Current concerns are primarily about preferential regimes which can be used for artificial profit shifting and about a lack of transparency in connection with certain rulings. The report sets out an agreed methodology to assess whether there is substantial activity. In the context of IP regimes such as patent boxes, agreement was reached on the nexus approach which uses expenditures as a proxy for substantial activity and ensures that taxpayers can only benefit from IP regimes where they engaged in research and development and incurred actual expenditures on such activities. The same principle can also be applied to other preferential regimes so that such regimes are found to require substantial activity where the taxpayer undertook the core income generating activities. In the area of transparency, a framework has been agreed for the compulsory spontaneous exchange of information on rulings that could give rise to BEPS concerns in the absence of such exchange. The results of the application of the existing factors applied by the FHTP, and the elaborated substantial activity and transparency factors, to a number of preferential regimes are included in this report.

Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report

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Author :
Publisher : OCDE
ISBN 13 : 9789264241466
Total Pages : 70 pages
Book Rating : 4.2/5 (414 download)

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Book Synopsis Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report by : OCDE,

Download or read book Transfer Pricing Documentation and Country-by-country Reporting, Action 13, 2015 Final Report written by OCDE, and published by OCDE. This book was released on 2015 with total page 70 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach and will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports

OECD/G20 Base Erosion and Profit Shifting Project Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2015 Final Report

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Author :
Publisher : OECD Publishing
ISBN 13 : 9264241175
Total Pages : 116 pages
Book Rating : 4.2/5 (642 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 116 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 4.

OECD/G20 Base Erosion and Profit Shifting Project Measuring and Monitoring Beps, Action 11 - 2015 Final Report

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Author :
Publisher : Org. for Economic Cooperation & Development
ISBN 13 : 9789264241336
Total Pages : 268 pages
Book Rating : 4.2/5 (413 download)

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Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Measuring and Monitoring Beps, Action 11 - 2015 Final Report by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Measuring and Monitoring Beps, Action 11 - 2015 Final Report written by OECD and published by Org. for Economic Cooperation & Development. This book was released on 2015-10-15 with total page 268 pages. Available in PDF, EPUB and Kindle. Book excerpt: There are hundreds of empirical studies finding evidence of tax-motivated profit shifting, using different data sources and estimation strategies. While measuring the scope of BEPS is challenging given its complexity and existing data limitations, a number of recent studies suggest that BEPS is responsible for significant global corporate income tax (CIT) revenue losses. This report assesses currently available data and concludes that significant limitations severely constrain economic analyses of the scale and economic impact of BEPS and improved data and methodologies are required. Noting these data limitations, a dashboard of six BEPS indicators has been constructed, using different data sources and assessing different BEPS channels. These indicators provide evidence that BEPS exists and has been increasing over time. New empirical analysis estimates that the scale of global CIT revenue losses could be between USD 100 and 240 billion annually at 2014 levels. The report also presents a toolkit to assist countries evaluate the fiscal effects of BEPS countermeasures. The research also finds significant non-fiscal economic distortions arising from BEPS. The report concludes by making recommendations regarding data and monitoring tools to improve the analysis of BEPS in the future

Double non-taxation and the use of hybrid entities

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Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 940354676X
Total Pages : 531 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Double non-taxation and the use of hybrid entities by : Leopoldo Parada

Download or read book Double non-taxation and the use of hybrid entities written by Leopoldo Parada and published by Kluwer Law International B.V.. This book was released on 2023-12-11 with total page 531 pages. Available in PDF, EPUB and Kindle. Book excerpt: The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation of foreign entities for tax purposes in the United States, Spain, Denmark, and Germany, as well as on the Poland/United States and Canada/United States tax treaties; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.

Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2016 Update

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Author :
Publisher : Organization for Economic Co-Operation & Development
ISBN 13 : 9789264268326
Total Pages : 0 pages
Book Rating : 4.2/5 (683 download)

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Book Synopsis Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2016 Update by : Organization for Economic Cooperation and Development

Download or read book Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2016 Update written by Organization for Economic Cooperation and Development and published by Organization for Economic Co-Operation & Development. This book was released on 2016-12-15 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 2015 Report established a common approach which directly links an entity's net interest deductions to its level of economic activity, based on taxable earnings before interest income and expense, depreciation and amortisation (EBITDA).