Oecd G20 Base Erosion And Profit Shifting Project Neutralising The Effects Of Hybrid Mismatch Arrangements PDF Download
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Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 103 |
Release | : 2014-09-16 |
Genre | : |
ISBN | : 9264218815 |
Download OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements Book in PDF, ePub and Kindle
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.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 458 |
Release | : 2015-10-05 |
Genre | : |
ISBN | : 9264241132 |
Download OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report Book in PDF, ePub and Kindle
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.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 104 |
Release | : 2017-07-27 |
Genre | : |
ISBN | : 9264278796 |
Download OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS Book in PDF, ePub and Kindle
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).
Author | : Oecd |
Publisher | : OCDE |
Total Pages | : 99 |
Release | : 2014-09-16 |
Genre | : Business & Economics |
ISBN | : 9789264218796 |
Download Neutralising the Effects of Hybrid Mismatch Arrangements Book in PDF, ePub and Kindle
This report 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. Once translated into domestic law, the recommendations in Part 1 of the report will neutralise the effect of cross-border hybrid mismatch arrangements that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part 1 of the report will be supplemented by a commentary, which will explain the recommended rules and illustrate their application with practical examples. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases. Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.
Author | : OCDE, |
Publisher | : OCDE |
Total Pages | : 454 |
Release | : 2015-10-15 |
Genre | : Corporations |
ISBN | : 9789264241084 |
Download Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report Book in PDF, ePub and Kindle
This report 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. Once translated into domestic law, the recommendations in Part 1 of the report will neutralise the effect of cross-border hybrid mismatch arrangements that produce multiple deductions for a single expense or a deduction in one jurisdiction with no corresponding taxation in the other jurisdiction. Part I of the report sets out recommendations for rules to address hybrid mismatches in respect of payments made under a hybrid financial instrument or payments made to or by a hybrid entity. It also recommends rules to address indirect mismatches that arise when the effects of a hybrid mismatch arrangement are imported into a third jurisdiction. The recommendations are supported by a commentary and examples to illustrate how they should apply. Part 2 of the report sets out proposed changes to the Model Convention that will ensure the benefits of tax treaties are only granted to hybrid entities (including dual resident entities) in appropriate cases. Part 2 also considers the interaction between the OECD Model Convention and the domestic law recommendations in Part 1.
Author | : Organization for Economic Development and Cooperation |
Publisher | : Organization for Economic Co-Operation & Development |
Total Pages | : 0 |
Release | : 2017 |
Genre | : Corporations |
ISBN | : 9789264277953 |
Download Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Book in PDF, ePub and Kindle
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.
Author | : Erik Pinetz |
Publisher | : Linde Verlag GmbH |
Total Pages | : 550 |
Release | : 2017-08-30 |
Genre | : Law |
ISBN | : 3709408814 |
Download Limiting Base Erosion Book in PDF, ePub and Kindle
Limiting base erosion from different viewpoints Hybrid mismatch arrangements, CFC rules, transfer pricing rules: “Limiting Base Erosion”, the general topic for the master theses of the part-time LL.M. program 2015-2017, has been one of the most controversial topics in international tax law ever since the initiation of the OECD BEPS Project in 2013. Even though the final reports of the 15 BEPS Actions were released by the OECD in as early as October 2015, the question how to effectively target base erosion practices still has not lost any of its topicality. Following the efforts of the OECD in developing a new international tax environment, the focus of attention has now partly shifted to the OECD Member countries that have to properly implement the OECD recommendations in their domestic laws as well as in their tax treaty practice. In this respect, a comprehensive analysis in the literature of all the issues related to base erosion proves to be of the utmost importance in order to provide practical guidance to the Member countries during that the process of implementation. This book deals especially with four key areas of interest:Limiting base erosion by neutralizing the effects of hybrid mismatch arrangementsLimiting base erosion by strengthening CFC rulesMeasures against base erosion via interest deductions and other financial paymentsLimiting base erosion by improving transfer pricing rules.On that basis, 27 concrete topics were chosen in order to address the four key areas of interest from different viewpoints. Base erosion and the challenges they present: read more in “Limiting Base Erosion”.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 44 |
Release | : 2013-07-19 |
Genre | : |
ISBN | : 9264202714 |
Download Action Plan on Base Erosion and Profit Shifting Book in PDF, ePub and Kindle
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.
Author | : Policy and Stratgey, Inland Revenue, New Zealand |
Publisher | : Policy and Strategy, Inland Revenue, New Zealand |
Total Pages | : 87 |
Release | : 2016-09-06 |
Genre | : |
ISBN | : 0478424361 |
Download Addressing hybrid mismatch arrangements Book in PDF, ePub and Kindle
Hybrid mistmatch arrangements are one of the main base erosion and profit shifting (BEPS) strategies used by some large international companies to pay little or no tax anywhere in the world. The OECD developed recommendations for anti-hybrid measures in its 15 point Base Erosion and Profit Shifting (BEPS) Action Plan. This Government discussion document seeks comments on how the OECD recommendations could be implemented in New Zealand. Part I of the document describes the problem of hybrid mismatch arrangements, the case for responding to the problem, and a summary of the OECD recommendations. Part II of the document explains the OECD recommendations in greater depth and discusses how they could be incorporated into New Zealand law.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 202 |
Release | : 2014-09-16 |
Genre | : |
ISBN | : 9264218785 |
Download OECD/G20 Base Erosion and Profit Shifting Project Addressing the Tax Challenges of the Digital Economy Book in PDF, ePub and Kindle
This book presents an analysis of the challenges the spread of the digital economy poses for international taxation.