BEPS – Implementation package
OECD published specific legislation recommendations in relation to BEPS Action no. 13.
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OECD published specific legislation recommendations in relation to BEPS Action no. 13.
Read moreIn this post, I summarize Action 2 of the BEPS package published by OECD in September the aim of which is to neutralize the effects of so-called hybrid mismatch arrangements, referred to hereinafter as “hybrid arrangements”, “hybrid structures” or simply as “hybrids”.
Read moreAction 6 of the OECD BEPS Action Plans deals with the prevention of double tax treaty (hereinafter: treaty) abuse. OECD finds that one of the most pressing BEPS issues is treaty abuse and especially the so-called treaty shopping (which basically means the use of tax benefits deriving from residence related and other differences between treaties) and for this reason, a separate action plan was dedicated to this matter.
Read moreTwo of the BEPS actions published so far (Actions 8 and 13) deal with transfer pricing. From these two, Action 13 specifically summarizes the BEPS guidance on transfer pricing documentation and country-by-country reporting.
Read moreIn the end of last year, Action 7 addressed preventing the artificial avoidance of PE status.
Read moreOn 27 January 2015, the Council of the European Union accepted Council Directive 2015/121 amending the Parent-Subsidiary Directive No. 2011/96/EU (hereinafter: the Directive) to combat abuse.
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