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EY Cross-Border Taxation Spotlight for Week ending 9

In late 2020, the OECD released a set of work-in-progress proposals aimed at reforming the international tax system. They were intended to address taxation challenges arising from the digitalisation of the economy and remaining concerns around base erosion and profit shifting (BEPS). BEPS 2.0 work despite the challenges of the COVID-19 pandemic, key political and technical issues still need to be resolved. This means that the initial timeline for delivering a consensus-based solution by the end of 2020 cannot be met. The Inclusive Framework on BEPS has now agreed to keep working to bring the process to a successful conclusion by BEPS 2.0: OECD updates proposal on the Unified Approach (Pillar 1) and progress of work on Minimum Taxation (Pillar 2) 03 Feb 2020 On the 31 st of January 2020 the OECD published a “Statement by the OECD/G20 Inclusive Framework (IF) on BEPS on the Two-Pillar Approach to Address the Tax Challenges Arising from the Digitalisation of the Economy”. Se hela listan på tax.kpmg.us BEPS 2.0, as currently contemplated, clearly goes beyond and is inconsistent with the DEMPE and control of risk rules. This does not mean that DEMPE and the BEPS risk rules are irrelevant: Pillar One would leave room for them with respect to the allocation of routine profits attributable to marketing intangibles, as well as some portion of non-routine profits.

Beps 2.0 timeline

Summary and Analysis of the OECD’s Work Program for BEPS 2.0 June 18, 2019 From a broad standpoint, agreement at the OECD will require countries to give up some measure of their own tax sovereignty on policies they have designed to minimize the distortionary effects of the corporate income tax. The PoW was endorsed by the G-20 in June 2019 and by the G-7 in July 2019. January 2020: This has been set as the target date for agreement to be reached on the outlines of the architecture of the solution. End of 2020: This has been set as the target date for full consensus agreement on the details of the solution. While the BEPS 2.0 project is still a distance away from agreement, some early clarity is emerging around the expected shape of the rules. There is a push towards reaching agreement in the second half of 2021, with some suggestion that the arrival of a new administration in Washington D.C. has made that more likely.

From tax avoidance to digital tax challenges .

EY Cross-Border Taxation Spotlight for Week ending 9

14. Digital Tax – European Perspective. Timeline.

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Executive summary.

The current work — often called BEPS 2.0 — aims to tackle tax issues arising from increasing digitalization of businesses and from other elements that allow multinationals (MNEs) to base erode or profit shift.
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In its press release, the OECD announced its proposals had the backing of the U.S., as well as China, Brazil, and India. BEPS practices cost countries 100-240 billion USD in lost revenue annually, which is the equivalent to 4-10% of the global corporate income tax revenue. Working together in the OECD/G20 Inclusive Framework on BEPS, over 135 countries are implementing 15 Actions to tackle tax avoidance, improve the coherence of international tax rules and ensure a more transparent tax environment.

European Parliament resolution on fair taxation in a digitalised and globalised economy: BEPS 2.0 (2019/2901(RSP)) The European Parliament, – having regard to Articles 4 and 13 of the Treaty on European Union (TEU), – having regard to Articles 107, 108, 113, 115 and 116 of the Treaty on the Functioning of the European Union (TFEU), TD 2016/6 Income tax: is an amount that is a cost in relation to a debt interest covered by paragraph 820-40(1)(a) of the Income Tax Assessment Act 1997 (ITAA 1997) deductible under section 25-90 of the ITAA 1997 (or, alternatively, under subsection 230-15(3) of the ITAA 1997) where that amount is incurred in earning income that meets the requirements of both section 23AH of the Income Tax Base Erosion & Profit Shifting (BEPS) The OECD and other multilateral forums are exploring options to resolve the current debate over policies that would adjust which countries can tax what share of income from multinational corporations.
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Document Grep for query ""Precarization via Digitalization?" and

On 31 January 2020, the Organisation for Economic Co-operation and Development (OECD) released a Statement by the Inclusive Framework on BEPS on the Two-Pillar Approach to Address the Tax Challenges Arising from In July 2013, the OECD published an Action Plan on Base Erosion and Profit Shifting (BEPS). This set out 15 BEPS actions, and on 5 October 2015 the OECD and G20 published final reports along with an explanatory statement outlining consensus recommendations that had been reached as part of the BEPS project. BEPS Action Plan: Action 15 - A multilateral instrument It may take some while for the impact of these recommendations to be fully applied in practice, but the BEPS Project and related developments are constantly leading to the need for business to take action (in some cases, urgent action) both to comply with new requirements and to consider

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This means that the initial timeline for delivering a consensus-based solution by the end of 2020 cannot be met. The Inclusive Framework on BEPS has now agreed to keep working to bring the process to a successful conclusion by BEPS 2.0: OECD updates proposal on the Unified Approach (Pillar 1) and progress of work on Minimum Taxation (Pillar 2) 03 Feb 2020 On the 31 st of January 2020 the OECD published a “Statement by the OECD/G20 Inclusive Framework (IF) on BEPS on the Two-Pillar Approach to Address the Tax Challenges Arising from the Digitalisation of the Economy”. Se hela listan på tax.kpmg.us BEPS 2.0, as currently contemplated, clearly goes beyond and is inconsistent with the DEMPE and control of risk rules. This does not mean that DEMPE and the BEPS risk rules are irrelevant: Pillar One would leave room for them with respect to the allocation of routine profits attributable to marketing intangibles, as well as some portion of non-routine profits.