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Our responses to BEPS discussion drafts
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With the debate having reached the highest levels of governments, and with growing attention from the media and the public, BEPS continues to grow in prominence and already, many tax law changes are taking effect around the globe. The OECD’s Action Plan on BEPS was published in July 2013 with a view to addressing perceived flaws in international tax rules. The 40 page Action Plan, which was negotiated and drafted with the active participation of its member states, contains 15 separate action points or work streams, some of which are further split into specific actions or outputs.
Whilst the OECD finalised its recommendations under the BEPS Action Plan in December 2015, work is ongoing as part of the OECD’s Inclusive Framework on BEPS. The Inclusive Framework brings together over 100 jurisdictions (including developing countries) to collaborate on the implementation of the BEPS Package. Members of the Inclusive Framework will develop a monitoring process for the four minimum standards - Country-by-Country (CbC) Reporting, preventing treaty abuse, resolution of treaty-related disputes and countering harmful tax practice - as well as put in place the review mechanisms for other elements of the BEPS Package.
Gaining consensus amongst such a large group on the go-forward is likely to be both difficult and time consuming. Many countries have already implemented, or are in the process of implementing, significant changes to their tax systems in line with the BEPS recommendations, adding a new layer of complexity to the international tax system. Multinational companies should be assessing the impact on business operations, and preparing to meet the challenge of the modern tax system.
As work on addressing BEPS continues globally, PwC will be providing strategic analysis of what BEPS means both here in Australia and throughout the Asia Pacific region, leveraging our network of international taxation, transfer pricing and tax controversy specialists from around the world to provide you with insights.
Australia is one of 76 jurisdictions that sign, or indicated its intention to sign, the Organisation for Economic Cooperation and Development (OECD) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) on 7 June 2017.
An update on the status of implementation of all BEPS-related measures in Australia, including those that originate from the OECD BEPS project recommendations and other standalone measures aimed at combating erosion of the tax base.
The Australian Taxation Office released final guidance on assessing the transfer pricing risk of hubs and centralised operating models.
We examine two new Bills that will significantly impact large multinationals with Australian investments.
With the common reporting standard (CRS) obligations commencing from 1 July 2017, we discuss the differences between the CRS and the Foreign Account Tax Compliance Regime.
Digital products and services provided to Australian consumers will soon be subject to GST. Are you and your business prepared for the changes ahead?
We share our insights into Australia's first '21st century' treaty and what it reveals about how the country will incorporate the OECD's BEPS recommendations in the future.
We examine the unilateral legislative actions taken by the UK via the Diverted Profits Tax, and Australia via the Multinational Anti-avoidance Law to immediately address perceived avoidance behaviors of prominent concern.
Under this unique design, specific transfer pricing and business information will be required to be reported in a standardized electronic form. Local Files based on a standard global template may need to be updated for Australia.
As the global tax landscape rapidly evolves, tax transparency has emerged as a key area of focus for governments and tax authorities around the world.
Is it time to proactively address your international tax risks, such as transfer pricing?
Key changes are anticipated in transfer pricing administration in China.
We analyse the measures most relevant to foreign investors and discuss the opportunities and matters which need to be considered.
Interpretation of the key messages delivered at the National Tax Work Conference on the Administration on Large Business Groups
How will your obligations change in light of the latest developments in transfer pricing administration and investigation?
A new stage of tax administration on large business groups in China
The new rules presents challenges for taxpayers in managing their APA applications.
Discussion Draft on the administrative measures on the due diligence procedures for non-residents' financial account information in tax matters is released for public opinion.
Multinational companies need to get ready for the challenge of the new requirements on transparency and substance-tax alignment.
SAT has issued new transfer pricing compliance requirements. What are the actions you should undertake as soon as possible?
The recently announced Indian Budget 2017 proposes significant amendments to Indian transfer pricing law. We take a deeper dive into the three key proposals.
How will foreign investors and multinational enterprises be affected by the Budget?
The general anti-avoidance rules will take effect on 1 April 2017, and the Indian Central Board of Direct Taxes has offered its opinions on the applicability and implementation.
The 2017 Tax Reform Proposal includes corporate tax measures which are intended to support investments and to reward companies for raising employees salaries.
In order to revitalize the economy as well as target a return of the government deficit to a surplus by 2010, the 2016 Tax Reform aims to support profitable companies by continuing to lower the corporate tax rate while also continuing to expand taxable base.
An outline of the revised transfer pricing documentation requirements in Japan, with reference to the relevant recommendations in the Action 13 Report.
Covering the latest developments such as the guidance on the CbCR requirements released by the MOSF, the rewritten corporate and individual income tax laws in draft form, the WTO Agreement of Trade Faciliation, and more.
Keep up with the recent topics that may impact your business, such as the latest transfer pricing developments.
New legislations have been introduced to require qualifying taxpayers in Korea to submit the Combined Report of International Transactions, consisting of a Master file, a Local file, and a Country-by-Country Report, for fiscal years commencing on or after January 1, 2016.
We explore the significant changes contained in the amended tax laws and the bills to amend the Presidential Decrees.
The Ministry of Strategy and Finance announced its proposal to amend the Law for the Coordination of International Tax Affairs to strengthen the requirements for documentation related to transfer pricing in Korea.
All domestic corporations and foreign corporations in Korea whose international related party transaction amounts exceed KRW 50 billion and sales revenue exceed KRW 100 billion are required to annually submit the Combined Report of International Transactions, which is comprised of the Master file and the Local file.
The Ministry of Strategy and Finance announced the amendments to the Law for the Coordination of International Tax Affairs to strengthen transfer pricing documentation requirements on 15 December 2015.
The Ministry of Strategy and Finance has introduced the Combined Report of International Transactions - what does this mean for transfer pricing documentation requirements in Korea?
Keep up with the recent topics that may impact your business, such as the latest transfer pricing documentation requirements, and the adoption of the Common Reporting Standard.
The reform proposals' intentions include boosting the sluggish economy and facilitating job creation, as well as to increase transparency regarding sources of tax revenue. We summarise the significant changes contained in these tax reform proposals.
We take a closer look at the Government's recent discussion documents for the next steps in the BEPS journey for New Zealand.
The New Zealand Government is proposing to make it harder for foreign multinationals to shift profits overseas without economic justification.
New Zealand is changing international tax rules and relationships. We explore what's next on the horizon.
On 6 September 2016, the Government released a discussion document outlining the proposals to address hybrid mismatch arrangements.
The 2017 National Budget's theme is 'responsible fiscal consolidation for future growth and development', and key components include projections for the PNG economy.
How will multinational enterprises with operations in Singapore be impacted by the latest developments?
Singapore has updated its Transfer Pricing Guideliens to incorporate the BEPS Actions developments.
Singapore tax authorities have issued long-awaited Singapore Country-by-Country reporting implementation guidance.
The Inland Revenue Authority of Singapore has released revised Transfer Pricing Guidelines, an update to those first published in Febrary 2006.
This decree represents the most important development with respect to Vietnam's transfer pricing regime in the last ten years.
Dive into the discussion draft and what it may mean for your organisation.
The BEPS Working Group in Vietnam is responsible for preparing action plans to implement the OECD's BEPS initiatives and overseeing the implementation process.
International Tax Leader, PwC Australia
Tel: +61 3 8603 6247
Global Tax Leader
Tel: +61 7 3257 5015
Partner, PwC Australia
Tel: +61 2 8266 0973