OECD: BEPS Webcast #5 is Now OnlineBy Robert Robillard - 16 December 2014
This blogpost originally appeared on rbrt.ca.
BEPS Webcast #5 is available here. Some highlights:
- Supplementary report on action #1 (digital economy) is due in 2015.
- Hybrid mismatch arrangements final report and transitional rules and commentary expected in September 2015.
- Report on treaty abuse (action #6) expected in September 2015 following the public consultation taking place at this time.
- The modified nexus approach for IP regime (somehow based on the CWI rule in the USA) is moving forward.
- Guidance on the implementation of CbC reporting for TP documentation (action #13) is expected in February 2015.
- A public consultation is coming on action #4 (interest deductibility).
- Work is beginning on a multilateral instrument (action #15)
- More discussion drafts are expected in 2015 on transfer pricing, risk and recharacterization; TP and commodity transactions, profit split uses in the context of a global value chain; and effective dispute resolution.
2015 is going to be a BEPS-tacular year indeed…
RBRT Inc. is all about transfer pricing. We specialize in transfer pricing, tax treaties and other international tax matters. Our services include transfer pricing documentation (transfer pricing policies and procedures, BEPS and C-doc), transfer pricing dispute resolution, tax treaty matters including double tax relief, tax treaty-based returns and waivers, advanced pricing agreement (APA), value chain management and TP planning, transfer pricing training. The information in this blog post is general information only. Data and information come from sources believed to be reliable but complete accuracy cannot be guaranteed. RBRT Inc. and the author are not responsible or liable for any error, omission or inaccuracy in such information. Readers should seek tax advice and tax counsel from RBRT Inc. as required.