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Including publication of guidance on MLI synthesised texts, reporting on preferential tax regimes, and gathering input on latest tax dispute resolution peer reviews.

  • New guidance on MLI synthesised texts for tax treaties provides an overview of the modifications to tax treaties under the terms of the BEPS multilateral instrument (MLI), to facilitate consistent preparation of synthesised texts. A note on withholding taxes clarifies that where the latest of the dates of entry into force for a pair of jurisdictions is 1 January 2019, the MLI will have effect for taxes withheld at source on or after 1 January 2019 (https://bit.ly/2z6Mbs0).
  • Report on review of 53 preferential tax regimes in connection with BEPS Action 5, which updates the 2017 progress report. The inclusive framework has also decided to resume its application of the ‘substantial activities’ test to zero-tax jurisdictions, whether or not these have preferential tax regimes. Originally part of the OECD’s 1998 report on harmful tax practices, the focus on substantial activities was relegated in importance following a change in the assessment criteria in 2002, before being elevated again by the BEPS project (https://bit.ly/2DHSeqP).
  • Input invited on seventh batch of tax dispute resolution peer reviews for monitoring minimum standards under BEPS Action 14. This batch involves Brazil, Bulgaria, China, Hong Kong, Indonesia, Papua New Guinea, Russia and Saudi Arabia. The deadline for submissions is 13 December 2018 (https://bit.ly/2FpACBU).
Issue: 1422
Categories: News , International taxes
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