The first 7 elements of the Action Plan released Sept 16 focus on helping countries to:
- ensure the coherence of corporate income taxation at the international level, through new model tax and treaty provisions to neutralise hybrid mismatch arrangements (Action 2);
- realign taxation and relevant substance to restore the intended benefits of international standards and to prevent the abuse of tax treaties (Action 6);
- assure that transfer pricing outcomes are in line with value creation, through actions to address transfer pricing issues in the key area of intangibles (Action 8);
- improve transparency for tax administrations and increase certainty and predictability for taxpayers through improved transfer pricing documentation and a template for country-by-country reporting (Action 13);
- address the challenges of the digital economy (Action 1);
- facilitate swift implementation of the BEPS actions through a report on the feasibility of developing a multilateral instrument to amend bilateral tax treaties (Action 15); and
- counter harmful tax practices (Action 5).
The OECD recommendations will be a key item on the agenda when G20 finance ministers next convene at a meeting hosted by Australia’s Finance Minister Joe Hockey on 20-21 September in Cairns, Australia.
The proposed measures were agreed after a transparent and intensive consultation process between OECD, G20 and developing countries and stakeholders from business, labour, academia and civil society organisations.
These recommendations may be impacted by decisions taken with respect to the remaining elements of the BEPS Action Plan, which are scheduled to be presented to G20 Governments for final approval in 2015. At that point Governments will also address implementation measures for the Action Plan as a whole.
For further information on the OECD/G20 Base Erosion and Profit Shifting Project, including an Explanatory Statement, a background document, FAQs and the first deliverables to the G20, go to: www.oecd.org/tax/beps-2014-deliverables.htm.