23 apr. 2018 — För att BEPS-åtgärderna ska få fullt genomslag krävs alltså att ändringar 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 Integritetsskyddsmyndigheten har tagit fram en policy och en plan för de

9 Mar 2017 In this article, the 15 Action Points BEPS are explained. We'll also summarize what actions have been taken so far (if any). limitation-on-benefits (LOB) provision in combination with a principal purposes test (

Background Chapter 3. February 2013, OECD and G20 countries adopted a 15-point Action Plan to address BEPS in September 2013. The Action Plan identified 15 actions along three key pillars: introducing coherence in the domestic rules that affect cross-border activities, reinforcing substance requirements in the existing international standards, and improving transparency In this respect, the PPT provision proposed under BEPS Action 6 is not an exception. In this master thesis the author continues the discussion on BEPS and its compatibility with EU law, focusing specifically on the PPT rule. The 1 OECD, Action Plan on Base Erosion and Profit Shifting (OECD Publishing 2013). Is BEPS Action 6 “Preventing Treaty abuse” compatible with the EU Law concept (PPT) in order to address other forms of treaty shopping situations that the ―Is Tax Avoidance the Same Thing under the OECD Base Erosion and Profit Shifting Action Plan, … The 15 Action Points BEPS. You can click on each point to go read more on a specific point, or … BEPS Action Plan 13 provides for a minimum threshold of consolidated annual turnover of EUR750 million for MNE groups to be obliged to comply with CbC reporting, which the Indian government also seeks to follow.

Beps action plan ppt

Feb 2013 . OECD publishes background report on Addressing BEPS. July 2013. Release of 15 Action Plans to Address BEPS. 2016 Onwards. Implementation, Monitoring and further work. July – August 2014.

In order to become more compliant with the BEPS Action Plan, companies with globally mobile employees should consider the following key actions: • Understand where you are today • Plan ahead • Establish specific rules • Document effectively • Ensure transfer pricing compliance 1 OECD BEPS action plan 3 2 Background 5 3 Key messages for Jersey based businesses 9 4 BEPS – Impact for Jersey 11 5 Next steps 14 6 Resources and contacts 16 7 Appendix 1 – BEPS action plan actions 19 8 Appendix 2 – Discussion questions 28 Base Erosion and Profit Shifting 10 September 2013 2 BEPS Action Plan 4 – Elements of the design and operation of the Group Ratio Rule - Public discussion draft 18 July 2016 Introduction and Background The discussion draft issued by the Organisation for Economic Co-operation and Development (OECD) on the Base Erosion Profit Shifting (BEPS) Action Plan 4 The October 2015 BEPS Deliverables On 5 October, the OECD released the final deliverables of their Base Erosion and Profit Shifting (BEPS) Action Plan This represents one of the most significant changes to the international corporate tax landscape since the League of Nations proposed the first bilateral tax treaty in 1928 Action 6 of the BEPS Action Plan identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns.

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.

for UPSC/IAS Mains Tilly International - International Corporate Taxation - BEPS Action Plan Download professional template for PowerPoint or Google slides in just a few minutes. We have the best collection of professional templates, charts, diagrams The Principal Purposes Test (PPT) in BEPS Action 6/MLI: Exploring Challenges arising from its Legal Implementation and Practical Application. Abstract: This Search results for: Chapter 4 writing a business plan ppt.

av J Wessman · 2021 — Arbetets titel: BEPS och aggressiv skatteplanering - En fallstudie om Google Endast PPT; Eller https://www.oecd.org/tax/beps/beps-actions/action8-10/.

Protection” (CBEP).

The G20 asked OECD to address this growing problem by creating this action plan to address base erosion and profit shifting. This plan identifies a series of domestic and international actions Europe: BEPS Action 13 Implementation Belgium CbCR/MF/LF Iceland CbCR Finland CbCR/MF/LF Bulgaria Greece Norway CbCR MF/LF Denmark CbCR/MF/LF Germany CbCR/MF/LF Switzerland CbCR MF/LF Luxembourg CbCR Netherlands CbCR/MF/LF U.K. CbCR/MF/LF Isle of Man CbCR MF/LF Ireland Guernsey CbCR CbCR Jersey CbCR France CbCR/MF/LF Portugal CbCR Gibraltar Shifting (BEPS Action Plan, OECD, 2013) in July 2013.The 40 page detailed report, which was negotiated and drafted with the active participation of its member states, contained 15 separate action plans or work streams, some of which were further split into specific Where we are in the BEPS project Launched two years ago with the BEPS Action Plan (July 2013) following the report Addressing BEPS (February 2013) First set of interim reports released in September 2014 Final BEPS Package to be delivered in October to G20 FM and in November 2015 to Leaders Post-2015 BEPS work 4 implementation of its Action Plan on BEPS. 1 While countries in Europe and North America may appear to have the strongest voices in the debate, many countries in Latin America are influencing— and being influencedby — the OECD BEPS Action Plan: Moving from talk to action in Europe Overview The OECD Action Plan on BEPS, introduced in 2013, set out 15 specific action points to ensure international tax rules are fit for an increasingly globalized, digitized business world and to prevent international companies from paying little or no tax.
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Ineffective/No CFC Rules. Maximise Deductions. Minimise Assets/Risks. Action 5. Action 2.

• 15 Actions. • OECD+G20. Anti-Tax Avoidance. (ATA).
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25 Aug 2020 The Multilateral Instrument (the MLI), an outcome of BEPS Action Plan 15, allows governments to amend various tax treaties without the need to

Subjects/Keywords: BEPS; Action 6; transactions aimed at avoiding tax; treaty abuse; LOB-rule; PPT-rule; general anti-avoidance rule (GAAR); BEPS;

Abstract: This Search results for: Chapter 4 writing a business plan ppt. to “back stage” ( unseen for that customer) and “front stage” (seen using the customer) activities.

Expected impact . on BEPS •BEPS Action Plan 6(‘BEPS6’)is a detailed report on ‘Preventingthe Granting of Treaty Benefits in Inappropriate Circumstances’ • Aims to address inappropriate granting of treaty benefits and potential treaty abuse strategies • As aminimum standard, it requires introduction of atitle and preamble to tax treaties Introduction to BEPS BEPS Action Plan • OECD actions organized into 15 “Action Items” • Action Items that may have most relevance for customs and trade - Action Item 3: Strengthen Controlled Foreign Corporation (“CFC”) Rules - Action Items 8, 9 and 10: Transfer Pricing Outcomes - Action Item 13: Transfer Pricing Documentation b | Special report on BEPS Introduction On 5 October 2015, the Organisation for Economic Co-operation and Development (OECD) issued a final package of reports in connection with its Action Plan to address Base Erosion and Profit Shifting (BEPS), as well as a plan for follow-up work and a timetable for implementation. The OECD’s BEPS Action Plan, OECD BEPS action plan Overview 5 10 September 2013Base Erosion and Profit Shifting BEPS action plan Comprehensive action plan published on 19 July 2013 and now endorsed by G20 in St Petersburg: • Identifies 15 actions that are required to address BEPS; • Sets deadlines for actions (the majority within 24 months); and Action to fight corporate tax avoidance has been deemed necessary in the OECD forum has and received further impetus through the G20/OECD Base e rosion and p rofit shifting action plan (known as BEPS). The BEPS action plan has 15 actions, covering eleme2015 - nts used in corporate tax avoidance practices and aggressive tax-planning schemes.