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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 initial peer review process was conducted in two stages. Stage 1 assessed countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focused on monitoring the follow-up of any recommendations resulting from jurisdictions' Stage 1 peer review report. Following the conclusion of the initial peer review process in 2022, a continued monitoring process has started whereby all Inclusive Framework member jurisdictions will be subject to continued monitoring: jurisdictions that have "meaningful MAP experience" would undergo a full peer review process once every four years and those that do not would undergo a two-stage simplified peer review process. This report reflects the outcome of Stage 1 of the simplified peer review of the implementation of the BEPS Action 14 Minimum Standard by Zambia.
This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.
This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy. It sets out the Inclusive Framework’s agreed direction of work on digitalisation and the international tax rules through to 2020. It describes how digitalisation is also affecting other areas of the tax system, providing tax authorities with new tools that are translating into improvements in taxpayer services, improving the efficiency of tax collection and detecting tax evasion.
This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
This report reflects the outcome of the stage 2 peer monitoring of the implementation of the Action 14 Minimum Standard by France.
This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.
Tax administration improvements have contributed significantly to a doubling of China’s tax-to-GDP ratio and the substantial reduction in taxpayers’ compliance costs since the mid-1990s. This paper describes the key features of China’s tax administration and their evolution over the last 20 years. It also identifes emerging challenges to the tax system and areas where further tax administration improvements are needed to sustain tax revenue and reduce taxpayers’ compliance costs in the future.
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).
This report contains revised standards for transfer pricing documentation incorporating a master file, local file, and a template for country-by-country reporting of revenues, profits, taxes paid and certain measures of economic activity. The revised standardised approach and will require taxpayers to articulate consistent transfer pricing positions and will provide tax administrations with useful information to assess transfer pricing and other BEPS risks, make determinations about where audit resources can most effectively be deployed, and, in the event audits are called for, provide information to commence and target audit enquiries. Country-by-country reports will be disseminated through an automatic government-to-government exchange mechanism. The implementation package included in this report sets out guidance to ensure that the reports are provided in a timely manner, that confidentiality is preserved and that the information is used appropriately, by incorporating model legislation and model Competent Authority Agreements forming the basis for government-to-government exchanges of the reports
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 initial peer review process was conducted in two stages. Stage 1 assessed countries against the terms of reference of the minimum standard according to an agreed schedule of review. Stage 2 focused on monitoring the follow-up of any recommendations resulting from jurisdictions' Stage 1 peer review report. Following the conclusion of the initial peer review process in 2022, a continued monitoring process has started whereby all Inclusive Framework member jurisdictions will be subject to continued monitoring: jurisdictions that have "meaningful MAP experience" would undergo a full peer review process once every four years and those that do not would undergo a two-stage simplified peer review process. This report reflects the outcome of Stage 1 of the simplified peer review of the implementation of the BEPS Action 14 Minimum Standard by Costa Rica.