Discussion draft on group ratio rule under BEPS Action 4: The OECD invites comments by 16 August 2016 on a discussion draft which deals with elements of the design and operation of the group ratio rule under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
XML schema for exchange of information on tax rulings (ETR XML Schema): The OECD has released its standardised XML schema for exchange of information on tax rulings between jurisdictions, under the framework established by Action 5 of BEPS (harmful tax practices). This framework covers all rulings that could give rise to BEPS concerns in the absence of compulsory spontaneous exchange and covers six categories of rulings: rulings related to preferential regimes; (ii) cross border unilateral APAs or other unilateral transfer pricing rulings; (iii) rulings giving a downward adjustment to profits; (iv) permanent establishment rulings; (v) conduit rulings; and (vi) any other type of ruling where the OECD Forum on Harmful Tax Practices agrees in the future that the absence of exchange would give rise to BEPS concerns. In some jurisdictions, exchange of information under this framework for future rulings started from 1 April 2016, with exchange for certain past rulings to be completed by 31 December 2016
XML schema for information exchanged under common reporting standard (CRS Status Message XML Schema): The OECD has released its standardised XML schema for providing structured feedback on exchanged Common Reporting Standard information, as well as the related user guide (see http://bit.ly/29QrhQO). Jurisdictions will rely on this schema for the first automatic exchanges of financial account information under the CRS, scheduled for September 2017.
Angola and Seychelles join the ‘inclusive framework’: On 7 July, Angola and the Seychelles became the 83rd and 84th members respectively of the inclusive framework on BEPS. See http://bit.ly/29CPybb.
Discussion draft on group ratio rule under BEPS Action 4: The OECD invites comments by 16 August 2016 on a discussion draft which deals with elements of the design and operation of the group ratio rule under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
XML schema for exchange of information on tax rulings (ETR XML Schema): The OECD has released its standardised XML schema for exchange of information on tax rulings between jurisdictions, under the framework established by Action 5 of BEPS (harmful tax practices). This framework covers all rulings that could give rise to BEPS concerns in the absence of compulsory spontaneous exchange and covers six categories of rulings: rulings related to preferential regimes; (ii) cross border unilateral APAs or other unilateral transfer pricing rulings; (iii) rulings giving a downward adjustment to profits; (iv) permanent establishment rulings; (v) conduit rulings; and (vi) any other type of ruling where the OECD Forum on Harmful Tax Practices agrees in the future that the absence of exchange would give rise to BEPS concerns. In some jurisdictions, exchange of information under this framework for future rulings started from 1 April 2016, with exchange for certain past rulings to be completed by 31 December 2016
XML schema for information exchanged under common reporting standard (CRS Status Message XML Schema): The OECD has released its standardised XML schema for providing structured feedback on exchanged Common Reporting Standard information, as well as the related user guide (see http://bit.ly/29QrhQO). Jurisdictions will rely on this schema for the first automatic exchanges of financial account information under the CRS, scheduled for September 2017.
Angola and Seychelles join the ‘inclusive framework’: On 7 July, Angola and the Seychelles became the 83rd and 84th members respectively of the inclusive framework on BEPS. See http://bit.ly/29CPybb.
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