The BEPS Monitoring Group

Posts tagged BEPS

Comments on the Model Rules for the GloBE

The agreement that countries wishing to do so will introduce a global anti-base erosion tax (GloBE) was a historic breakthrough. Such concerted counter-measures could put a brake on the competition to reduce tax on the profits of multinational enterprises (MNEs), and perhaps even reverse it. They could also potentially assist a renewed attempt to rebalance the allocation of rights to tax MNE profits according to where they have real activities and value is created. Although the GloBE opens a new way forward, its direction and destination remain uncertain, and a longer-term solution will require continuing efforts on all sides.

In view of the importance of this initiative, we are publishing now our analysis of the Model Rules for the GloBE published on 20 December 2021, although neither the Commentary nor the Implementation Framework have yet been released. These rules are highly detailed and complex, and in our view it is both unrealistic and undesirable to expect any country simply to enact them verbatim in its domestic laws. The OECD cannot legislate for the world, nor is there a global tribunal that could resolve the many practical and interpretation issues they will inevitably raise.

Action 1BEPS Monitoring GroupFebruary 9, 2022BEPS, global minimum taxComment

Tax Challenges of the Digital Economy

The BMG has made a new submission on Tax Challenges of the Digital Economy in response to the Request for Comments by the OECD in connection with the work of the Task Force on the Digital Economy, preparing a report for the G20.

Action 1, Unitary TaxationBEPS Monitoring GroupOctober 18, 2017BEPS, multinational companies, tax avoidance, unitary taxationComment

Offshore Indirect Transfers of Assets

The BMG has now submitted its comments on the discussion draft from the Platform for Collaboration on Tax for a Toolkit on Taxation of Offshore Indirect Transfers of assets.

Action 15, Action 6BEPS Monitoring GroupOctober 6, 2017BEPS, BMG, multinational companies, OECD request for comments, tax evasion and avoidanceComment

Comments on the Draft Revised Guidance on Profit Splits

The BMG has made a submission on the Draft Revised Guidance on Profit Splits.

Action 10, Action 8BEPS Monitoring GroupSeptember 14, 2017BEPS, BMG, multinational companies, OECD request for comments, tax evasion and avoidance, Transfer PricingComment

Comments on Draft Additional Guidance on Attribution of Profits to a Permanent Establishment

The BMG has made a submission on Attribution of Profits to a Permanent Establishment in response to the OECD Discussion Draft.

Action 7, Action 8BEPS Monitoring GroupSeptember 14, 2017BEPS, BMG, multinational companies, OECD request for comments, tax evasion and avoidance, Transfer PricingComment

Hard-to-Value Intangibles

The BMG has submitted comments on a further discussion draft from the OECD relating to transfer pricing of hard-to-value intangibles.

Action 8BEPS Monitoring GroupJune 22, 2017BEPS, BMG, multinational companies, OECD request for comments, tax evasion and avoidance, Transfer PricingComment

Presentation to the Inclusive Framework on BEPS

The BMG participated in the plenary meeting of the Inclusive Framework on BEPS, held in The Netherlands on Thursday 22 June.

Action Plan, Enlarged Framework, Unitary TaxationBEPS Monitoring GroupJune 22, 2017BEPS, BMG, multinational companies, tax evasion and avoidance, Transfer Pricing Comment

The European Commission’s Proposals for a Common and Consolidated Corporate Tax Base

The BMG has now published its comments on the CCCTB – the European Commission’s proposals for Common Corporate Tax Base, and for a Common Consolidated Corporate Tax Base.

Unitary TaxationBEPS Monitoring GroupMay 16, 2017BEPS, Controlled Foreign Corporations, multinational companies, tax evasion and avoidance, Transfer Pricing, unitary taxationComment

The Multilateral Convention on BEPS

The BMG has now published its explanation and Analysis of MC-BEPS to implement the tax treaty related provisions of the BEPS project.

Action 7BEPS Monitoring GroupMarch 16, 2017BEPS, multinational companies, tax avoidanceComment

Monitoring measures to end base erosion and profit shifting by transnational corporations