7 mars 2019 — The Directive is based on the BEPS OECD Action 12. The first occasion for filing is latest August 31, 2020. However, reportable arrangements

* DTC BEPS Sub-committee: Prof Annet Wanyana Oguttu, Chair DTC BEPS Subcommittee (University of South Africa 8 OECD/G20 2015 Final Report on Actions 8-10 at 10.

116 Se Dodwell, Bill, OECD Tax Alert : Final BEPS reports released: an overall perspective, 144 Jfr BEPS Action 8-10, s. 15. 145 Art. 113 OECD, Report on Transfer Pricing and Multinational Enterprises (1979). Pricing Outcomes with Value Creation - Actions 8-10 Final Reports (2015). 12 okt.

6 intangible investments, and causes fiscal spillovers between countries and wasteful and inefficient expenditure of resources on tax engineering. This report by the OECD/G20 Inclusive Framework on BEPS presents the current state of play in progressing its mandate, covering the period from July 2017 to June 2018. It outlines on the major Session 5 of 8 part OECD BEPS seriesSign up for upcoming live broadcasts or watch all archived webcasts on demand at http://www.ey.com/webcasts. Executive summary. On 29 January 2019, the Organisation for Economic Co-operation and Development (OECD) released Harmful Tax Practices – 2018 Progress Report on Preferential Regimes (the 2018 Progress Report), approved by the Inclusive Framework on Base Erosion and Profit Shifting (BEPS).The purpose of this document is to provide an update to the 2017 Progress Report and to report the The CbC report should be submitted within the 12-month period after the last day of reporting fiscal year.

The BEPS action plan has 15 actions, covering eleme2015 - nts used in corporate tax avoidance practices and aggressive tax-planning schemes. The implementation of the BEPS action plan was designed to be flexible, as a consequence of its adoption by consensus. Recommendations made in BEPS reports range from minimum standards In July 2013, the OECD published an Action Plan on Base Erosion and Profit Shifting (BEPS).

The Report states that it is critical that the tools and data available to measure and monitor BEPS should be improved, as well as evaluating the impact of the countermeasures developed under the BEPS Action Plan. The Report also makes a number of recommendations that will improve the analysis of available data. The Report

10 Jun - Slovakia: MLI and real estate clause in tax treaties. 6 Jun - Panama: Country-by-country reporting Data and research on tax including income tax, consumption tax, dispute resolution, tax avoidance, BEPS, tax havens, fiscal federalism, tax administration, tax treaties and transfer pricing., The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. BEPS Action Plan: Action 15 - A multilateral instrument It may take some while for the impact of these recommendations to be fully applied in practice, but the BEPS Project and related developments are constantly leading to the need for business to take action (in some cases, urgent action) both to comply with new requirements and to consider the ways in which they do business in different The BEPS-driven revisions to the OECD Transfer Pricing Guidelines (contained in the final report for Actions 8–10) should also be taken into account in planning and pricing, though the extent to which the revised guidelines represent a significant change in law will differ by country (depending on whether a country formally subscribes to the guidelines and the extent to which the guidelines The CbC report should be submitted within the 12-month period after the last day of reporting fiscal year. Failure to submit the CbC report will trigger an initial penalty of AED1m (US$274,000), and AED10,000 (US$2,740) to be applied daily to a maximum of AED250,000 (US$68,500) for failure to file the CbC report.

Jan 29, 2019 CbC reporting is also bringing changes to how multinationals approach transfer pricing documentation. Before the BEPS Action 8-10 and 13

Actions 8-10 – Transfer pricing On 5 October 2015, the G20/OECD published 13 final reports and an explanatory statement outlining consensus actions under the base erosion and profit shifting (BEPS) project.

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The stated purpose of the Final Report is to align the transfer pricing methods to allocate profits to the most important, value creating economic activities. 2016-09-01 The 2015 BEPS Action Plan reports on Action 4 (Limiting base erosion involving interest deductions and other financial payments) and Actions 8-10 (Aligning Transfer Pricing Outcomes with Value Creation) mandated follow-up work on the transfer pricing aspects of financial transactions.In particular, Action 4 … Result: Action Point 8-10 and 13 (October 2015) Page 4 Action 8-10 overview . Page 5 New transfer pricing principles (Actions 8-10) Overview of the final report BEPS Action 8, 9 and 10 Assure that transfer pricing outcomes are in line with value creation Action 8: Intangibles Wider and clearer definition of 2020-08-17 As noted in today’s OECD release, the follow-up work of the two reports was mandated by the OECD/G20 report Aligning transfer pricing outcomes with value creation (October 2015) as part of the final BEPS package. The report contained revised guidance—such as transfer pricing issues relating to transactions involving intangibles; contractual arrangements including the contractual allocation Oecd beps actions 8- 10 final report Home » Find Documents » ICC Comment on BEPS Actions 8 Implementation Guidance on High Value Intangibles Draft discussion provides guidance on implementing approaches to pricing transfers of high-value intangibles described in Chapter 6 of the OECD Transfer Pricing Guidelines, addressing the clarification and strengthening of guidance on adjusting price Under the mandate of the Report on Actions 8-10 of the BEPS Action Plan (“Aligning Transfer Pricing Outcomes with Value Creation”), Working Party No. 6 (“WP6”) has produced a non-consensus discussion draft on financial transactions.. Comments are due by September 7, 2018.

The final report on BEPS Actions 8–10: Aligning Transfer Pricing The OECD submits a progress report to the G-20 finance ministers and leaders at their respective meetings and summits.
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11/02/2020 – Today, the OECD released the report Transfer Pricing Guidance on Financial Transactions: Inclusive Framework on BEPS: Actions 4, 8-10..

7 Jul - OECD: Discussion draft under BEPS Action 7, profits attributed to 2015-08-10 OECD. On 15 July 2019, the OECD announced that it is now gathering input on the implementation of the BEPS Action 14 minimum standard in relation to the review of the ninth batch of jurisdictions (Andorra, Anguilla, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau (China), Morocco and Tunisia) and invites taxpayers to submit their input related to their 3 See 2013 OECD/G20 BEPS report on action 11 at 58-60. 4 Ibid. 5 OECD/G20 2015 Final Report on Action 11 at 16. 6 intangible investments, and causes fiscal spillovers between countries and wasteful and inefficient expenditure of resources on tax engineering.