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OECD Tax Talks #1 - 16 June 2016

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The document summarizes discussions from an OECD Tax Talks event on international tax issues. It provides updates on the implementation of the BEPS project including country progress, guidance development, and the establishment of an inclusive framework for monitoring and peer review. It also discusses developments in tax transparency, such as the increasing number of countries committing to automatic information exchange. Finally, it outlines collaboration between organizations on domestic resource mobilization and next steps for the international tax agenda.

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OECD Tax Talks CENTRE FOR TAX POLICY AND ADMINISTRATION 16 June 2016 2:00pm – 3:00pm (CEST)
Ask questions and comment throughout the webcast 2 Join the discussion Via email CTP.Contact@oecd.org Via Twitter using #OECDTaxTalks
Update on international tax agenda Presented by Pascal Saint-Amans, Director of the Centre for Tax Policy and Administration BEPS package Presented by Achim Pross, Head of International Co-operation and Tax Administration Domestic resource mobilisation & collaboration of international organisations Presented by Ben Dickinson, Head of Tax and Development Programme 3 Today’s topics and speakers
Update on the BEPS Project Tax transparency Forum on Tax Administration G20 Tax Policy Symposium 4 UPDATE ON THE INTERNATIONAL TAX AGENDA
• Actions 8-10 implemented (incl. update of the Transfer Pricing Guidelines, 23 May 2016) • Countries have started implementation – For example on Country-by-Country Reporting, Hybrid Mismatches and Preferential regimes • The EU action: mandatory exchange of rulings; Country-by-Country Reporting; and the draft Anti-Tax Avoidance Directive • The Multilateral Instrument on BEPS tax treaty-related measures is well underway: – 96 countries are participating in its negotiation, covering more than 2000 bilateral treaties – 31 May 2016, Discussion draft released – 7 July 2016, Public consultation to be held 5 Implementation of the BEPS Project
What is the inclusive framework? • Opening of the Committee on Fiscal Affairs (CFA) to interested and committed countries and jurisdictions • Members participate on an equal footing in the decision- making body (CFA) and the technical working groups 6 Implementation of the BEPS Project contd. 6
• The inclusive framework: – standard-setting – review and monitor the implementation of the BEPS package – support implementation • 8 toolkits are being developed • Further guidance on CBCR implementation • First meeting in Kyoto: 30 June – 1 July 7 Implementation of the BEPS Project contd.
• Latest countries to commit to implementing automatic exchange of information (CRS): Bahrain, Lebanon, Nauru, Panama and Vanuatu – Now 101 countries and jurisdictions committed for 2017 or 2018 • Multilateral Competent Authorities Agreement on Automatic Exchange of Financial Account Information: – 82 jurisdictions have signed – Russian Federation and Israel are the most recent signatories 8 Tax transparency
• New Global Forum members: Lebanon and Paraguay – Now 134 members • Multilateral Convention on Mutual Administrative Assistance in Tax Matters: – 96 Countries and Jurisdictions participate – Jamaica and Uruguay are the most recent signatories – A further 4 countries will sign soon, with an additional 6 countries recently expressing their interest to join. 9 Tax transparency contd.
• New G20 mandates, April 2016: – The OECD to establish objective criteria by July 2016 to identify non-cooperative jurisdictions with respect to tax transparency – The Global Forum and the Financial Action Task Force to make initial proposals by October 2016 on ways to improve the implementation of international standards on transparency Increasing focus on beneficial ownership information 10 Tax transparency contd.
• 44 tax commissioners met in Beijing, China, in May 2016 • JITSIC collaboration to tackle Panama Papers • Common Transmission System for tax authorities to exchange information 11 Forum on Tax Administration
• 23 July 2016 • Ministerial-level • Exploring tax policy’s role in – Achieving innovation-driven and inclusive growth – Increasing tax certainty to promote trade and investment in a world where value creation is changing 12 G20 Tax Policy Symposium
THE BEPS PACKAGE Review and monitoring Country progress and guidance on implementation 13
• What is BEPS peer review? – Peer Review of jurisdictions to assess their compliance with the 4 BEPS minimum standards – Terms of reference and assessment methodologies for reviews to be defined for each minimum standard – Public reporting of outcomes 14 BEPS Actions: Peer review
• Gathering data on the implementation of the other elements of the BEPS package • Including on the impact of BEPS and measures to counter-BEPS (Action 11) • Continuation of Task Force on the Digital Economy (Action 1) 15 BEPS Actions: Monitoring
Overview BEPS Actions 16
• Multilateral Competent Authorities Agreement on Country-by-Country Reporting signed by 39 jurisdictions • Mechanism for exchanging CbC Reports (through the Common Transmission System) 17 Focus on: Action 13 48 jurisdictions have either implemented or intend to implement legislation
• 20 countries • >90% MAP cases covered Peer review of the Minimum Standard • Development of Terms of Reference well advanced • Reviews expected to begin in 2016 Supplementary commitment for mandatory binding MAP arbitration Focus on: Action 14
DOMESTIC RESOURCE MOBILISATION & COLLABORATION OF INTERNATIONAL ORGANISATIONS 19
• Platform for Collaboration on Tax – Concept Note, 19 April 2016 – Report for G20 Finance Ministers in July with recommendations on effective implementation of technical assistance programs, and funding for tax projects. 20 Domestic resource mobilisation
21 Platform for Collaboration on Tax: 8 Toolkits 1. Report on Tax Incentives - delivered 2. Toolkit on Transfer Pricing Comparability Including supplementary work on mineral pricing 3. Report on Indirect transfers of Assets 4. Toolkit on Transfer Pricing Documentation 5. Toolkit on Tax Treaty Negotiations 6. Toolkit on Base Eroding Payments 7. Toolkit on Supply Chain Management 8. Toolkit on BEPS risk assessment
WHAT’S NEXT? 22
• Kyoto meeting of inclusive framework • July 2016: More OECD Tax Talks • 23 July 2016: G20 Tax Policy Symposium 23 What’s next? 31 May 2016 Discussion draft Action 15 Multilateral Instrument 7 July 2016 Public consultation Action 15 Multilateral Instrument 6 July 2016 Discussion draft Action 2 Group ratio rule 18 July 2016 Discussion draft Action 4 Interest (banking and insurance sectors) Wk 8 Aug Discussion draft Action 2 Branch mismatch arrangements Under preparation: Discussion drafts on Actions 7, 8-10: Profit split method and profit attribution

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OECD Tax Talks #1 - 16 June 2016

  • 1. OECD Tax Talks CENTRE FOR TAX POLICY AND ADMINISTRATION 16 June 2016 2:00pm – 3:00pm (CEST)
  • 2. Ask questions and comment throughout the webcast 2 Join the discussion Via email [email protected] Via Twitter using #OECDTaxTalks
  • 3. Update on international tax agenda Presented by Pascal Saint-Amans, Director of the Centre for Tax Policy and Administration BEPS package Presented by Achim Pross, Head of International Co-operation and Tax Administration Domestic resource mobilisation & collaboration of international organisations Presented by Ben Dickinson, Head of Tax and Development Programme 3 Today’s topics and speakers
  • 4. Update on the BEPS Project Tax transparency Forum on Tax Administration G20 Tax Policy Symposium 4 UPDATE ON THE INTERNATIONAL TAX AGENDA
  • 5. • Actions 8-10 implemented (incl. update of the Transfer Pricing Guidelines, 23 May 2016) • Countries have started implementation – For example on Country-by-Country Reporting, Hybrid Mismatches and Preferential regimes • The EU action: mandatory exchange of rulings; Country-by-Country Reporting; and the draft Anti-Tax Avoidance Directive • The Multilateral Instrument on BEPS tax treaty-related measures is well underway: – 96 countries are participating in its negotiation, covering more than 2000 bilateral treaties – 31 May 2016, Discussion draft released – 7 July 2016, Public consultation to be held 5 Implementation of the BEPS Project
  • 6. What is the inclusive framework? • Opening of the Committee on Fiscal Affairs (CFA) to interested and committed countries and jurisdictions • Members participate on an equal footing in the decision- making body (CFA) and the technical working groups 6 Implementation of the BEPS Project contd. 6
  • 7. • The inclusive framework: – standard-setting – review and monitor the implementation of the BEPS package – support implementation • 8 toolkits are being developed • Further guidance on CBCR implementation • First meeting in Kyoto: 30 June – 1 July 7 Implementation of the BEPS Project contd.
  • 8. • Latest countries to commit to implementing automatic exchange of information (CRS): Bahrain, Lebanon, Nauru, Panama and Vanuatu – Now 101 countries and jurisdictions committed for 2017 or 2018 • Multilateral Competent Authorities Agreement on Automatic Exchange of Financial Account Information: – 82 jurisdictions have signed – Russian Federation and Israel are the most recent signatories 8 Tax transparency
  • 9. • New Global Forum members: Lebanon and Paraguay – Now 134 members • Multilateral Convention on Mutual Administrative Assistance in Tax Matters: – 96 Countries and Jurisdictions participate – Jamaica and Uruguay are the most recent signatories – A further 4 countries will sign soon, with an additional 6 countries recently expressing their interest to join. 9 Tax transparency contd.
  • 10. • New G20 mandates, April 2016: – The OECD to establish objective criteria by July 2016 to identify non-cooperative jurisdictions with respect to tax transparency – The Global Forum and the Financial Action Task Force to make initial proposals by October 2016 on ways to improve the implementation of international standards on transparency Increasing focus on beneficial ownership information 10 Tax transparency contd.
  • 11. • 44 tax commissioners met in Beijing, China, in May 2016 • JITSIC collaboration to tackle Panama Papers • Common Transmission System for tax authorities to exchange information 11 Forum on Tax Administration
  • 12. • 23 July 2016 • Ministerial-level • Exploring tax policy’s role in – Achieving innovation-driven and inclusive growth – Increasing tax certainty to promote trade and investment in a world where value creation is changing 12 G20 Tax Policy Symposium
  • 13. THE BEPS PACKAGE Review and monitoring Country progress and guidance on implementation 13
  • 14. • What is BEPS peer review? – Peer Review of jurisdictions to assess their compliance with the 4 BEPS minimum standards – Terms of reference and assessment methodologies for reviews to be defined for each minimum standard – Public reporting of outcomes 14 BEPS Actions: Peer review
  • 15. • Gathering data on the implementation of the other elements of the BEPS package • Including on the impact of BEPS and measures to counter-BEPS (Action 11) • Continuation of Task Force on the Digital Economy (Action 1) 15 BEPS Actions: Monitoring
  • 17. • Multilateral Competent Authorities Agreement on Country-by-Country Reporting signed by 39 jurisdictions • Mechanism for exchanging CbC Reports (through the Common Transmission System) 17 Focus on: Action 13 48 jurisdictions have either implemented or intend to implement legislation
  • 18. • 20 countries • >90% MAP cases covered Peer review of the Minimum Standard • Development of Terms of Reference well advanced • Reviews expected to begin in 2016 Supplementary commitment for mandatory binding MAP arbitration Focus on: Action 14
  • 20. • Platform for Collaboration on Tax – Concept Note, 19 April 2016 – Report for G20 Finance Ministers in July with recommendations on effective implementation of technical assistance programs, and funding for tax projects. 20 Domestic resource mobilisation
  • 21. 21 Platform for Collaboration on Tax: 8 Toolkits 1. Report on Tax Incentives - delivered 2. Toolkit on Transfer Pricing Comparability Including supplementary work on mineral pricing 3. Report on Indirect transfers of Assets 4. Toolkit on Transfer Pricing Documentation 5. Toolkit on Tax Treaty Negotiations 6. Toolkit on Base Eroding Payments 7. Toolkit on Supply Chain Management 8. Toolkit on BEPS risk assessment
  • 23. • Kyoto meeting of inclusive framework • July 2016: More OECD Tax Talks • 23 July 2016: G20 Tax Policy Symposium 23 What’s next? 31 May 2016 Discussion draft Action 15 Multilateral Instrument 7 July 2016 Public consultation Action 15 Multilateral Instrument 6 July 2016 Discussion draft Action 2 Group ratio rule 18 July 2016 Discussion draft Action 4 Interest (banking and insurance sectors) Wk 8 Aug Discussion draft Action 2 Branch mismatch arrangements Under preparation: Discussion drafts on Actions 7, 8-10: Profit split method and profit attribution