OCDE publicó un Plan de acción contra la erosión de la base imponible y el traslado de beneficios (Plan de Acción BEPS, OCDE, 2013) en julio de 2013. La Acción 1 del mencionado proyecto apunta a diseñar un plan de trabajo para abordar los desafíos fiscales que plantea la economía digital.

5 Dec 2019 Implementation of BEPS Action Plan in India Minimum standard on treaty abuse: principal purpose test (PPT), PPT plus simplified limitation.

8 A key outcome of this work was the recommendation that treaties include anti-abuse rules, including the so-called “principal purposes test” (PPT), which denies treaty benefits if one of the principal 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. Therefore, this article analyses Action 6, particularly the inclusion of the PPT within the BEPS Action Plan. It then identifies the critiques of the PPT clause, defines treaty abuse, i.e. what the PPT should ideally be preventing, and then addresses the criticisms of the PPT and reformulates the PPT on this basis. 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.

Beps action plan ppt

Action 6 of BEPS introduced the principal purpose test (PPT) as one of the Minimum Standards to be implemented by the countries participating in the BEPS Inclusive Framework. The PPT has been also introduced in the Multilateral Instrument (MLI) in force since 1 July 2018. Action Plan Particulars 7 Preventing the Artificial Avoidance of Permanent Establishment Status 8- 10 Aligning Transfer Pricing Outcomes with Value Creation 11 Measuring and Monitoring BEPS 12 Mandatory Disclosure Rules 13 Transfer Pricing Documentation and Country- by -Country Reporting 14 Making Dispute Resolution Mechanisms More Effective BEPS Actions Developed in the context of the OECD/G20 BEPS Project, the 15 actions set out below equip governments with domestic and international rules and instruments to address tax avoidance, ensuring that profits are taxed where economic activities generating the profits are performed and where value is created. Overview of BEPS Action Report 6 PPT •PPT provides that benefits under the tax treaty shall be denied if it is reasonable to conclude that obtaining the treaty benefit was one of the principal purposes of any arrangement • However, it provides a carve-out for granting such treaty benefits if it is in 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 The BEPS Action Plan includes 15 actions to address BEPS in a comprehensive manner and sets deadlines to implement these actions. 2. The BEPS Action Plan identifies treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns.

Action Plan Particulars 5 Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance 6 Preventing the Granting of Treaty Benefits in Inappropriate Circumstances 13 Transfer Pricing Documentation and Country- by -Country Reporting 14 Making Dispute Resolution Mechanisms More Effective BEPS ² LIST OF

5 Oct 2015 The Organisation for Economic Co-operation and Development (OECD) has today unveiled its much anticipated (and long awaited) proposals 16 Jun 2015 A group established to monitor the BEPS Action Plan for the reform of the taxation of Comments on BEPS Action 6: Prevent Treaty Abuse a combination of a principal purpose test (PPT) and an LoB provision, or (ii) a 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 ( 30 Jul 2013 The OECD's Committee on Fiscal Affairs (CFA) has published its Action Plan to address Base Erosion and Profit Shifting (BEPS). 24 Oct 2016 Action Plan Pie PowerPoint Charts consists of the areas in which data is written.

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 (

BEPS aim at aligning taxation with substance, by ensuring that taxable profits can't be shifted away and Action Plan 5 focuses on revamping the work on harmful tax practices with a priority on improving transparency, including compulsory spontaneous exchange on rulings to preferential regimes and on requiring substantial activity for any preferential regime. 8 Action Plan 7 under BEPS and its Impact on India 1. 707, Pearl Best Heights II, C-9 Netaji Subhash Place, PitamPura, New Delhi – 110034 E-mail Id: gaurav@jgarg.com, Website: www.jgarg.com 1 ACTION PLAN 7 UNDER BEPS AND ITS IMPACT ON INDIA With change in the ways of doing business, globalization, presence of digital world, traditional international tax principles stands limited and needs to Taxation is at the core of countries' sovereignty, but in recent years, multinational companies have avoided taxation in their home countries by pushing activities abroad to low or no tax jurisdictions. 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.

Back to top… BEPS Action Point 11: Measuring and monitoring BEPS 2020-07-01 · The OECD followed it by publishing a draft action plan in July 2013 which finalized in October 2015. The BEPS action plan identifies 15 action plans to address BEPS comprehensively and also sets a deadline to implement those. In this Blog, we shall be discussing the following: BEPS Action Plan 1: Addressing the challenges of the Digital Economy.
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Action Plan on Base Erosion and Profit Shifting(BEPS Action Plan, OECD . 2013) identified 15 actions to address BEPS in a comprehensive manner. In October 2015, the G20 Finance Ministers endorsed the BEPS package which includes the report on Action. 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.

Action 2. Action 8-10.
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Therefore, this article analyses Action 6, particularly the inclusion of the PPT within the BEPS Action Plan. It then identifies the critiques of the PPT clause, defines treaty abuse, i.e. what the PPT should ideally be preventing, and then addresses the criticisms of the PPT and reformulates the PPT on this basis.

OECD Action Plan on Base Erosion & Profit Shifting (BEPS) How will BEPS impact your captive? Charles Winter, Aon and Tracey Skinner, BT Airmic Conference position that the PPT has already been applicable to existing treaties based on A bill that was designed to align with the BEPS action plan (particularly Action 22 Feb 2020 MLI, PPT, Tax Treaty, Treaty Abuse, BEPS Action 6. KLASIFIKASI JEL Erosion and Profit Shifting (BEPS) Action Plans in the late 2015, global 29 Jul 2019 Action 6 of BEPS introduced the principal purpose test (PPT) as one of The impact of BEPS Actions and MLI in the treaty network will be one 12 Dec 2018 This follows the BEPS Action 6 final report on 'Preventing the Thus far, the majority of signatories to the MLI have opted for a PPT only. 5 Dec 2019 Implementation of BEPS Action Plan in India Minimum standard on treaty abuse: principal purpose test (PPT), PPT plus simplified limitation.