The OECD has released public comments on the BEPS discussion draft on action 14 (making dispute resolution mechanisms more effective). See the 413-page document.
In the first of a new series, Allan Cinnamon provides a global review of tax treaty developments, including the UK’s DPT.
Mark Middleditch (Allen & Overy) provides the monthly round-up of tax developments affecting the City
William Morris (BIAC) reflects on the lessons learned to date that will contribute to a successful outcome for the BEPS project
The OECD has published the following discussion drafts as part of the BEPS project:
Hey, a new tax. As a tax adviser, that sounds like pretty good news. (Shame it is so bad for the country, but that's politics for you).
The OECD has released its discussion draft on the use of profit splits in the context of global value chains as part of the work on BEPS Action 10.
It is clear that the government feels the need to ‘do something’. However, it is much less clear that the diverted profits tax proposals is the best thing to do, as Heather Self (Pinsent Masons) explains.
Traditional treaty principles that allocate taxing rights between residence and source states, which have long formed the cornerstone of international tax consensus, are undergoing rapid re-evaluation, writes Jonathan Schwarz (Temple Tax Chambers)
How does the ‘nexus’ approach, proposed by the UK and Germany for future IP regimes, differ from the ‘transfer pricing’ approach of the UK patent box, asks Peter Denison-Pender (MMP Tax Ltd)