[COMING SOON] ๐ถ๐๐๐๐๐๐๐ก๐ ๐๐๐ฅ ๐๐ก๐๐ก๐๐ ๐ก๐๐๐ 2024: Stay tuned for data on corporate income tax, MNE activity, BEPS practices, tax rates, & more!
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This publication is a key output of Action 11 of the OECD/G20 BEPS Project, which has helped to improve the measurement and monitoring of multinational tax avoidance. It includes data on corporate tax rates, revenues, effective tax rates, tax treaties, and tax incentives for R&D and innovation amongst other data series. The publication also includes anonymised and aggregated Country-by-Country Reporting (CbCR) data providing an overview of the global tax and economic activities of thousands of MNE groups operating worldwide. The 2024 edition presents new data series on IP regimes, BEPS implementation, the distribution of low-taxed profit, as well as the 2021 CbCR data.
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๐๏ธ Available 11 July 2024 ๐ 11:00 CEST
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โก๏ธ https://oe.cd/corptaxstats
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#CorpTaxStats#OECDtax#OECD#tax#CorporateIncomeTax#CIT#data#internationaltax#MNEs#GlobalMinimumTax#CbCR#BEPS#RandD#ETR#data#taxavoidance#internationaltax
[COMING SOON] ๐ถ๐๐๐๐๐๐๐ก๐ ๐๐๐ฅ ๐๐ก๐๐ก๐๐ ๐ก๐๐๐ 2023: Stay tuned for data on corporate income tax, MNE activity, BEPS practices, tax rates, & more!
ย
This publication is a key output of Action 11 of the OECD/G20 BEPS Project, which seeks to improve the measurement and monitoring of multinational tax avoidance. It includes data on corporate tax rates, revenues, effective tax rates, tax treaties, and tax incentives for R&D and innovation amongst other data series. The publication also includes anonymised and aggregated country-by-country reporting (CbCR) data providing an overview of the global tax and economic activities of thousands of MNE groups operating worldwide. The 2023 edition of the database contains two years of anonymised and aggregated CbCR data (financial years 2019 and 2020), improving the timeliness of the CbCR data, as well as additional information on the location of low-taxed profits on a jurisdiction-by-jurisdiction basis around the world.
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๐๏ธ Available 21 November 2023 ๐ 11:00 CET
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โก๏ธ https://oe.cd/corptaxstats
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#CorpTaxStats#OECDtax#OECD#tax#corporatetax#CIT#CbCR#BEPS#RandD#ETR#data#taxavoidance#internationaltax
OECD/G20 Inclusive Frameworkย - Pillar One Amount B
In October 2021, the OECD/G20 Inclusive Framework (IF) on BEPS agreed to simplify and streamline the application of the armโs length principle to baseline marketing and distribution activities, with a particular focus on the needs of low-capacity jurisdictions.
Following that mandate, this report contains the guidance on โSpecial considerations for baseline distribution activitiesโ which is incorporated into the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022 as an Annex to Chapter IV.
Jurisdictions can choose to apply the simplified and streamlined approach to qualifying transactions of eligible baseline distributors. The guidance in this report sets out the characteristics of in-scope distributors, which cannot, for example, assume certain economically significant risks or own unique and value intangibles. Moreover, certain activities may exclude a distributor from the scope, such as the distribution of commodities or digital goods. The simplified and streamlined approach provides a pricing framework whereby a 3-step process determines a return on sales for in-scope distributors. Finally, the report also provides guidance on documentation, transitional issues, and tax certainty considerations.
#beps#Pillar1AmountB
Director, OECD Centre for Tax Policy and Administration
I am pleased to announce the release of the report on Amount B of Pillar One.
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Agreed upon by the members of the OECD/G20 Inclusive Framework on BEPS, this new report provides a simplified and streamlined approach to apply the armโs length principle to baseline marketing and distribution activities at country-jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention.
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The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions.
Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.
๐ Access the report and the Reader's Guide โก๏ธ https://oe.cd/5qm
๐๏ธ Read the web announcement โก๏ธ https://oe.cd/5qk#OECDtax#OECD#tax#OECDP1#Pillar1#internationaltax#taxreform#AmountB#TrustinTax#TaxCertainty#TransferPricing#BEPS
Amount B is out!
I would not have used the terms โsimplifiedโ and โstreamlinedโ to describe such a measure. The report counts more than 50 pagesโฆso even if we should welcome the initiative, it results in new challenges for multinational companies, tax authorities and tax professionals.
[OUT NOW] Pillar One - Amount B
ย
In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the armโs length principle to in-country baseline marketing and distribution activities.
This new report provides a simplified approach and guidance for the application of the armโs length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention.
The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions.
Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.
๐ Access the report and the Reader's Guide โก๏ธ https://oe.cd/5qm
๐๏ธ Read the web announcement โก๏ธ https://oe.cd/5qk#OECDtax#OECD#tax#OECDP1#Pillar1#internationaltax#taxreform#AmountB#TrustinTax#TaxCertainty#TransferPricing#BEPS
Today, the OECD released the report on Amount B of Pillar One.
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The new report provides a simplified and streamlined approach to apply the armโs length principle to baseline marketing and distribution activities at country-jurisdiction level, and is expected to reduce transfer pricing disputes and compliance costs, and, consequently, increase tax certainty for taxpayers especially in low-capacity jurisdictions.
The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention, and the content has been incorporated into the OECD Transfer Pricing Guidelines.
To access the full content, check below the OECD publication:
[OUT NOW] Pillar One - Amount B
ย
In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the armโs length principle to in-country baseline marketing and distribution activities.
This new report provides a simplified approach and guidance for the application of the armโs length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention.
The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions.
Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.
๐ Access the report and the Reader's Guide โก๏ธ https://oe.cd/5qm
๐๏ธ Read the web announcement โก๏ธ https://oe.cd/5qk#OECDtax#OECD#tax#OECDP1#Pillar1#internationaltax#taxreform#AmountB#TrustinTax#TaxCertainty#TransferPricing#BEPS
Thereโs fresh news in the TP world! The report on Amount B was published today. It will be incorporated in an annex to the OECD TPGs. The implementation of Amount B should provide benefits to taxpayers and tax administrations (especially in low capacity jurisdictions) in the context of baseline marketing and distribution activities.
[OUT NOW] Pillar One - Amount B
ย
In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the armโs length principle to in-country baseline marketing and distribution activities.
This new report provides a simplified approach and guidance for the application of the armโs length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention.
The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions.
Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.
๐ Access the report and the Reader's Guide โก๏ธ https://oe.cd/5qm
๐๏ธ Read the web announcement โก๏ธ https://oe.cd/5qk#OECDtax#OECD#tax#OECDP1#Pillar1#internationaltax#taxreform#AmountB#TrustinTax#TaxCertainty#TransferPricing#BEPS
What has suprised me is that OECD has included all the reservations, notes and objections made by India in this Report which is now a part of the TP Guidelines as the TPG has up to now been a consensus document without reservations or objections. Suprisingly also as the streamlined approach is optional and jurisdictions do not have to follow it (as New Zealand has already announced). Including any reservations even in an Annex to a chapter on administrative approaches is potentially the start of a slippery slope which will further undermine the increasingly fragile global consensus of the TPG and damage tax certainty.
[OUT NOW] Pillar One - Amount B
ย
In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the armโs length principle to in-country baseline marketing and distribution activities.
This new report provides a simplified approach and guidance for the application of the armโs length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention.
The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions.
Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.
๐ Access the report and the Reader's Guide โก๏ธ https://oe.cd/5qm
๐๏ธ Read the web announcement โก๏ธ https://oe.cd/5qk#OECDtax#OECD#tax#OECDP1#Pillar1#internationaltax#taxreform#AmountB#TrustinTax#TaxCertainty#TransferPricing#BEPS
Director, OECD Centre for Tax Policy and Administration
I am pleased to announce the release of the report on Amount B of Pillar One.
ย
Agreed upon by the members of the OECD/G20 Inclusive Framework on BEPS, this new report provides a simplified and streamlined approach to apply the armโs length principle to baseline marketing and distribution activities at country-jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention.
ย
The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions.
Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.
๐ Access the report and the Reader's Guide โก๏ธ https://oe.cd/5qm
๐๏ธ Read the web announcement โก๏ธ https://oe.cd/5qk#OECDtax#OECD#tax#OECDP1#Pillar1#internationaltax#taxreform#AmountB#TrustinTax#TaxCertainty#TransferPricing#BEPS
Amount B released and incorporated into the OECD TP Guidelines. Option to apply it for countries starting 2025. Significant reservations from India included in the report.
To be confirmed by reality the following statements
"Nothing in the guidance contained in this report should be construed as a basis to interpret the application of the general principles in the remainder of the OECD Transfer Pricing Guidelines with respect to any transactions, nor should this guidance be interpreted as revising those principles".
[...]
"The fact that an activity does not qualify for the simplified and streamlined approach under this guidance should not be interpreted to mean that such activity generates lower or higher returns than is permissible under the simplified and streamlined approach or that the returns applied for in-scope taxpayers represents a โfloorโ or a โceilingโ for returns to distribution activities in general."
[OUT NOW] Pillar One - Amount B
ย
In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the armโs length principle to in-country baseline marketing and distribution activities.
This new report provides a simplified approach and guidance for the application of the armโs length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention.
The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions.
Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.
๐ Access the report and the Reader's Guide โก๏ธ https://oe.cd/5qm
๐๏ธ Read the web announcement โก๏ธ https://oe.cd/5qk#OECDtax#OECD#tax#OECDP1#Pillar1#internationaltax#taxreform#AmountB#TrustinTax#TaxCertainty#TransferPricing#BEPS
The report released today by OECD Tax, which introduces two options for implementation for jurisdictions that opt into the simplified and streamlined approach from January 2025, describes the circumstances under which a distributor is within scope of Amount B including cases where it also performs certain non-distribution activities, such as manufacturing. It also sets out the activities that may exclude a distributor from the scope of the simplified and streamlined approach, such as the distribution of commodities or digital goods
#Pillar1#OECD#AmountB
[OUT NOW] Pillar One - Amount B
ย
In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting agreed to simplify and streamline the application of the armโs length principle to in-country baseline marketing and distribution activities.
This new report provides a simplified approach and guidance for the application of the armโs length principle at jurisdiction level. The report is accompanied by conforming changes to the Commentary on Article 25 of the OECD Model Tax Convention.
The simplified approach is expected to reduce transfer pricing disputes, compliance costs, and enhance tax certainty for tax administrations and taxpayers alike, particularly across low-capacity jurisdictions.
Content from the report has now been incorporated into the OECD Transfer Pricing Guidelines.
๐ Access the report and the Reader's Guide โก๏ธ https://oe.cd/5qm
๐๏ธ Read the web announcement โก๏ธ https://oe.cd/5qk#OECDtax#OECD#tax#OECDP1#Pillar1#internationaltax#taxreform#AmountB#TrustinTax#TaxCertainty#TransferPricing#BEPS
Tax Analyst | PNG CPA Certified (Pursing AU CPA) - Tax preparer and accountant Specialist. Passionate in tax advising, resolving tax audits and outstanding taxpayer compliance matters.
1moVery informative