OECD/G20 Base Erosion and Profit Shifting Project Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report

OECD/G20 Base Erosion and Profit Shifting Project Preventing the Artificial Avoidance of Permanent Establishment Status, Action 7 - 2015 Final Report PDF

Author: OECD

Publisher: OECD Publishing

Published: 2015-10-05

Total Pages: 51

ISBN-13: 9264241221

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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 7.

Preventing the Artificial Avoidance of Permanent Establishment Status

Preventing the Artificial Avoidance of Permanent Establishment Status PDF

Author: OCDE,

Publisher: OCDE

Published: 2015-10-22

Total Pages: 48

ISBN-13: 9789264241213

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This report includes changes to the definition of permanent establishment in the OECD Model Tax Convention that will address strategies used to avoid having a taxable presence in a country under tax treaties. These changes will ensure that where the activities that an intermediary exercises in a country are intended to result in the regular conclusion of contracts to be performed by a foreign enterprise, that enterprise will be considered to have a taxable presence in that country unless the intermediary is performing these activities in the course of an independent business. The changes will also restrict the application of a number of exceptions to the definition of permanent establishment to activities that are preparatory or auxiliary nature and will ensure that it is not possible to take advantage of these exceptions by the fragmentation of a cohesive operating business into several small operations; they will also address situations where the exception applicable to construction sites is circumvented through the splitting-up contracts between closely related enterprises.

OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report

OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances, Action 6 - 2015 Final Report PDF

Author: OECD

Publisher: OECD Publishing

Published: 2015-10-05

Total Pages: 106

ISBN-13: 9264241698

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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 6.

OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances

OECD/G20 Base Erosion and Profit Shifting Project Preventing the Granting of Treaty Benefits in Inappropriate Circumstances PDF

Author: OECD

Publisher: OECD Publishing

Published: 2014-09-16

Total Pages: 112

ISBN-13: 9264219129

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This report from the OECD/G20 Base Erosion and Profit Shifting project examines the issue of preventing the granting of treaty benefits in inappropriate circumstances. It includes proposed changes to the OECD Model Tax convention and summarises progress to date.

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

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

Author: OECD

Publisher: OECD Publishing

Published: 2015-10-05

Total Pages: 75

ISBN-13: 9264241159

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

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

Author: OECD

Publisher: OECD Publishing

Published: 2015-10-05

Total Pages: 74

ISBN-13: 9264241485

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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 Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report

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

Author: OECD

Publisher: OECD Publishing

Published: 2015-10-05

Total Pages: 458

ISBN-13: 9264241132

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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.

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

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 PDF

Author: OECD

Publisher: OECD Publishing

Published: 2015-10-05

Total Pages: 85

ISBN-13: 9264241191

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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.

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