Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Branch Mismatch Arrangements Action 2 Inclusive Framework On Beps
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Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Branch Mismatch Arrangements Action 2 Inclusive Framework On Beps
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-07-27
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Branch Mismatch Arrangements Action 2 Inclusive Framework On Beps written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-07-27 with categories.
This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).
Neutralising The Effects Of Branch Mismatch Arrangements Action 2
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Author : Organization for Economic Development and Cooperation
language : en
Publisher: Organization for Economic Co-Operation & Development
Release Date : 2017
Neutralising The Effects Of Branch Mismatch Arrangements Action 2 written by Organization for Economic Development and Cooperation and has been published by Organization for Economic Co-Operation & Development this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017 with Corporations categories.
This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report). Branch mismatches arise where the ordinary rules for allocating income and expenditure between the branch and head office result in a portion of the net income of the taxpayer escaping the charge to taxation in both the branch and residence jurisdiction. Unlike hybrid mismatches, which result from conflicts in the legal treatment of entities or instruments, branch mismatches are the result of differences in the way the branch and head office account for a payment made by or to the branch. The 2017 report identifies five basic types of branch mismatch arrangements that give rise to one of three types of mismatches: deduction / no inclusion (D/NI) outcomes, double deduction (DD) outcomes, and indirect deduction / no inclusion (indirect D/NI) outcomes. This report includes specific recommendations for improvements to domestic law intended to reduce the frequency of branch mismatches as well as targeted branch mismatch rules which adjust the tax consequences in either the residence or branch jurisdiction in order to neutralise the hybrid mismatch without disturbing any of the other tax, commercial or regulatory outcomes. The annexes of the report summarise the recommendations and set out a number of examples illustrating the intended operation of the recommended rules.
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements Action 2 2015 Final Report
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2015-10-05
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements Action 2 2015 Final Report written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-10-05 with categories.
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 2.
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2014-09-16
Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-09-16 with categories.
This report, produced by the OECD/G20 Project on Base Erosion and Profit Shifting sets out recommendations for domestic rules to neutralise the effect of hybrid mismatch arrangements and includes changes to the OECD Model Tax Convention to address such arrangements.
Oecd G20 Base Erosion And Profit Shifting Project Making Dispute Resolution More Effective Map Peer Review Report The Bahamas Stage 2 Inclusive Framework On Beps Action 14
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2022-04-14
Oecd G20 Base Erosion And Profit Shifting Project Making Dispute Resolution More Effective Map Peer Review Report The Bahamas Stage 2 Inclusive Framework On Beps Action 14 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-04-14 with categories.
This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by the Bahamas.
Oecd G20 Base Erosion And Profit Shifting Project Making Dispute Resolution More Effective Map Peer Review Report Luxembourg Stage 2 Inclusive Framework On Beps Action 14
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2020-04-09
Oecd G20 Base Erosion And Profit Shifting Project Making Dispute Resolution More Effective Map Peer Review Report Luxembourg Stage 2 Inclusive Framework On Beps Action 14 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-04-09 with categories.
This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Luxembourg, which is accompanied by a document addressing the implementation of best practices.
Oecd G20 Base Erosion And Profit Shifting Project Making Dispute Resolution More Effective Map Peer Review Report Viet Nam Stage 2 Inclusive Framework On Beps Action 14
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2022-09-13
Oecd G20 Base Erosion And Profit Shifting Project Making Dispute Resolution More Effective Map Peer Review Report Viet Nam Stage 2 Inclusive Framework On Beps Action 14 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-09-13 with categories.
Under BEPS Action 14, members of the OECD/G20 Inclusive Framework on BEPS have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to the interpretation and application of tax treaties. The BEPS Action 14 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review and monitoring process. The peer review process is conducted in two stages. Stage 1 assesses countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focuses on monitoring the follow-up of any recommendations resulting from jurisdictions' Stage 1 peer review report. This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by Viet Nam.
Oecd G20 Base Erosion And Profit Shifting Project Making Dispute Resolution More Effective Map Peer Review Report British Virgin Islands Stage 2 Inclusive Framework On Beps Action 14
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2022-04-14
Oecd G20 Base Erosion And Profit Shifting Project Making Dispute Resolution More Effective Map Peer Review Report British Virgin Islands Stage 2 Inclusive Framework On Beps Action 14 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-04-14 with categories.
This report reflects the outcome of the Stage 2 peer monitoring of the implementation of the BEPS Action 14 Minimum Standard by the British Virgin Islands.
Oecd G20 Base Erosion And Profit Shifting Project Making Dispute Resolution More Effective Map Peer Review Report Turkey Stage 2 Inclusive Framework On Beps Action 14
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2021-05-25
Oecd G20 Base Erosion And Profit Shifting Project Making Dispute Resolution More Effective Map Peer Review Report Turkey Stage 2 Inclusive Framework On Beps Action 14 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-05-25 with categories.
This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by Turkey.
Oecd G20 Base Erosion And Profit Shifting Project Country By Country Reporting Compilation Of Peer Review Reports Phase 2 Inclusive Framework On Beps Action 13
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2019-09-03
Oecd G20 Base Erosion And Profit Shifting Project Country By Country Reporting Compilation Of Peer Review Reports Phase 2 Inclusive Framework On Beps Action 13 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-09-03 with categories.
The peer review of the Action 13 Minimum Standard is proceeding in stages with three annual reviews in 2017, 2018 and 2019. The phased review process follows the phased implementation of CbC Reporting. Each annual peer review process will therefore focus on different aspects of the three key areas under review: the domestic legal and administrative framework, the exchange of information framework, and the confidentiality and appropriate use of CbC reports. This second annual peer review report reflects the outcome of the second review which considered all aspects of implementation. It contains the review of 116 jurisdictions which provided legislation or information pertaining to the implementation of CbC Reporting.