Developed in the context of the OECD/G20 BEPS Project, the 15 BEPS actions equip governments with domestic and international instruments to address tax avoidance, ensuring that profits are taxed where economic activities generating the profits are performed and where value is created. Under the inclusive framework, over 100 countries and jurisdictions are now collaborating to implement the BEPS measures and tackle BEPS.
The OECD publishes the comments received on the discussion draft on branch mismatch structures under Action 2 of the BEPS Action Plan.
On 3 April 2015, interested parties were invited to comment on the discussion draft on Action 3 (Strengthening CFC Rules) of the BEPS Action Plan. The OECD is grateful to the commentators for their input and now publishes the comments received.
Public comments are invited on a discussion draft which deals with action 3 (Strengthening CFC Rules) of the BEPS Action Plan.
Public comments are invited on a discussion draft which deals with action 12 (Mandatory Disclosure Rules) of the BEPS Action Plan.
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Comments on Action item 2 - Hybrid Mismatch Arrangements
While after-tax hedging is not, of itself, aggressive - being generally a straightforward risk management technique - the report recognises that it can also be used as a feature of aggressive tax planning (ATP) schemes. ATP schemes based on after-tax hedging pose a threat to countries’ revenue base.