The LOB rule and the PPT rule can be implemented where appropriate and not already covered by domestic law. It is not the intention of BEPS Action 6 that already existing treaties be renegotiated if the current treaty is sufficient to both contracting states in addressing treaty shopping.

Action 1 Tax Challenges Arising from Digitalisation. Addressing the tax challenges raised by digitalisation is currently the top priority for the OECD/G20 Inclusive Framework, and has been a key area of focus of the BEPS Project since its inception. This work has delivered several important outputs covering both direct and indirect tax issues.

Plan Released. +. CbC Discussion. Initiated.

OECD Action Plan on BEPS — action items Action 1 — Address tax challenges of the digital economy Action 2 — Neutralize effects of hybrid mismatch arrangements Action 3 — Strengthen controlled foreign company (CFC) rules Action 4 — Limit base erosion via interest deductions and other financial payments The 2015 Action 5 Report (OECD, 2015) is one of the four BEPS minimum standards. Each of the four BEPS minimum standards is subject to peer review in order to ensure timely and accurate implementation and thus safeguard the level playing field. All members of the Inclusive Framework on BEPS commit to implementing the Action 5 • Action 11: Establish methodologies to collect and analyse data on BEPS and the actions to address it • Action 12: Require taxpayers to disclose their aggressive tax planning arrangements • Action 13: Re-examine transfer pricing documentation • Action 14: Make dispute resolution mechanisms more effective • Action 15: Develop a BEPS Project. Feb 2013 .

Mar 9, 2017 BEPS Action Point 1: Address the tax challenges of the digital economy (LOB) provision in combination with a principal purposes test (PPT),

Please find attached short summaries with regard to the different BEPS action points together with our observations and the respective developments in Switzerland. Our first issue is related to Action 1 of the BEPS Action Plan which calls for work to address the tax challenges of the digital economy.

Dec 12, 2018 This follows the BEPS Action 6 final report on 'Preventing the one of the following approaches: (1) a PPT; (2) a PPT and either a simplified or

kallat Principal Purpose Test (PPT), det vill säga att en avtalsförmån kan nekas of any arrangement or transaction that resulted directly or indirectly in that Här kommer ytterligare en artikel om OECD:s slutrapporter inom BEPS-projektet. I detta nummer sammanfattas rapporten gällande Action 6 & 15. i) en kombination av LOB- och PPT-regler, ii) endast en PPT regel eller iii) av A Lindgren · 2016 — 1.1.1 Vad är OECD? 4.3.1 Bakgrund till BEPS-‐projektets action 7 .

ActionPlan1–Budget2016proposal • In order to tax e-commerce transactions of non-residents, an “Equalisation Levy” in line with the recommendation of the OECD BEPS Action Plan 1 is proposed to be applied • Equalisation Levy would be 6% of the amount of consideration for “specified services” provided by a non-resident The 15 Action Points BEPS 1.
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This PPT rule is also included in the Multilateral Convention to implement tax treaty * Dennis Weber is a professor of European corporate tax law at the Uni- Developing a Multilateral Instrument on BEPS (Action 15). The 2014 BEPS Package will be presented to the G20 Finance Ministers at their meeting in Cairns, Australia, on September 20 and 21, and then (if approved) to the G20 Leaders at their meeting in Brisbane in November 2014. The remaining eight BEPS Action Plan deliverables are due in 2015.

General 1 — Albaeco.
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The 2015 Action 5 Report (OECD, 2015) is one of the four BEPS minimum standards. Each of the four BEPS minimum standards is subject to peer review in order to ensure timely and accurate implementation and thus safeguard the level playing field. All members of the Inclusive Framework on BEPS commit to implementing the Action 5

Projected completion of approximately ⅓ of Action Plan . December 2015 . Completion of remainder of Action Plan . 2016 and forward . Monitoring, additional/on-going actions . BEPS Update and Impacts on Jersey .