OECD Council approves the 2017 updates to OECD model tax convention
The Organisation for Economic Cooperation and Development (OECD), on 18 December 2017, released the 2017 edition of its Model Tax Convention on Income and Capital (MTC 2017). MTC 2017 is an update to the Model Tax Convention issued in 2014, and consolidates the changes resulting from the Base Erosion and Profits Shifting (BEPS) Project under the following action plans: • Action 2 (Neutralising the Effects of Hybrid Mismatch Arrangements) • Action 6 (Preventing the Granting of Treaty Benefits in Inappropriate Circumstances) • Action 7 (Preventing the Artificial Avoidance of Permanent Establishment Status) and • Action 14 (Making Dispute Resolution More Effective) While it is not binding on countries, OECD’s Model Tax Convention on Income and Capital provides clear modalities for taxing income and capital, with a view to eliminate double taxation in different jurisdictions. It is expected that MTC 2017 will be a basis for negotiating future bilateral tax treaties…
The OECD releases 2017 Revised Transfer Pricing Guidelines
The Organisation for Economic Cooperation and Development (OECD), on 10 July 2017, released the revised edition of the Transfer Pricing (TP) Guidelines for Multinational Enterprises and Tax Administrations.