Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Branch Mismatch Arrangements Action 2 Inclusive Framework On Beps
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OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS by OECD Pdf
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).
Neutralising the Effects of Branch Mismatch Arrangements, Action 2 by Organization for Economic Development and Cooperation Pdf
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.
OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report by OECD Pdf
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 Neutralising the Effects of Hybrid Mismatch Arrangements by OECD Pdf
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.
OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Canada (Stage 2) Inclusive Framework on BEPS: Action 14 by OECD Pdf
This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Canada, 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, The Bahamas (Stage 2) Inclusive Framework on BEPS: Action 14 by OECD Pdf
This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by the Bahamas.
OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Switzerland (Stage 2) Inclusive Framework on BEPS: Action 14 by OECD Pdf
This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Switzerland, 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, Turkey (Stage 2) Inclusive Framework on BEPS: Action 14 by OECD Pdf
This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Turkey.
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 by OECD Pdf
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.
OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Viet Nam (Stage 2) Inclusive Framework on BEPS: Action 14 by OECD Pdf
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 Viet Nam.
OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Bulgaria (Stage 2) Inclusive Framework on BEPS: Action 14 by OECD Pdf
This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Bulgaria.
OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Luxembourg (Stage 2) Inclusive Framework on BEPS: Action 14 by OECD Pdf
This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Luxembourg, which is accompanied by a document addressing the implementation of best practices.
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 by OECD Pdf
This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Argentina.
OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Ireland (Stage 2) Inclusive Framework on BEPS: Action 14 by OECD Pdf
This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Ireland.
OECD/G20 Base Erosion and Profit Shifting Project Making Dispute Resolution More Effective – MAP Peer Review Report, Belgium (Stage 2) Inclusive Framework on BEPS: Action 14 by OECD Pdf
This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Belgium, which is accompanied by a document addressing the implementation of best practices which can be accessed on the OECD website.
