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Action 3. Strengthen CFC rules. Action 4. Limit base erosion via interest deductions and other financial payments. Action 5.

An invitation for comments was published on the OECD Website on 18 December 2014, with a deadline of 6 February 2015. 2015-10-23 3 28 July 2016 BEPS ACTION 4 - DISCUSSION DRAFT ON APPROACHES TO ADDRESS BEPS INVOLVING INTEREST IN THE BANKING AND INSURANCE SECTORS The report on Action 4, Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, establishes a common approach to tackling BEPS involving interest, but highlights a number of OECD BEPS Action Plan: moving from talk to action in the European region — 2016 Overview The OECD Action Plan on BEPS, introduced in 2013, set out 15 specific action points to ensure international tax rules are fit for an increasingly globalized, digitized business world and to prevent international companies from paying little or no tax. The BEPS project consists of 15 action plans with 4 minimum standards, agreed to by all participating countries who have committed to consistent implementation. Some measures can be used immediately, others require renegotiating bilateral tax treaties . Country-by-Country Reporting: Country implementation summary read.kpmg.us/global-tax-reform Key: Implemented Draft bills Intentions to implement No development Total Count: 76 Countries 4 Countries 8 Countries • Namibia • Panama • Rwanda • Trinidad & Tobago • Ukraine • Uganda 2014-09-16 2019-09-09 BEPS Action 4 in the UK The draft legislation: A summary. Key points of note: — Confirmed some areas that have changed following consultation responses — Included the first details on the administrative and compliance process — Not yet complete, BEPS Action 13: Country implementation summary (1) Dates provided as an example for an entity with December 31st fiscal year end. (2) If a CbyC effective date is listed and filing date is BLANK, please see the Country Detail tab to determine the first filing deadline.

Counter harmful tax practices more effectively, taking into account transparency and substance.

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The Action 4 recommendations aim to limit base erosion through the use of interest expense to achieve excessive This article analyses BEPS Action 4 and article. 4 of the EU ments for an interest limitation rule based on Action 4 In summary, the aforementioned countries. PDF | This article is to examine the approach of OECD Action plan on BEPS. analysis into two sections, to examine the anatomy of base erosion problems- first section, base Also see, Infra, note 4 [Shee boon Law argues: “profits of BEPS Action 4 called for recommendations on best practices in the design of rules to prevent corporate Our panel will provide an overview of these changes Action 4: Limiting Base Erosion Involving Interest Deductions and Other Executive Summary of specific Recommendations on OECD BEPS Packages.

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The Action Item 4: Interest Deductions Summary Limiting Base Erosion Involving Interest Deductions and Other Financial Payments – common approaches based on best practices for preventing base erosion through the use of interest expense. Action 4 of the BEPS plan addresses perceived harmful use of financing arrangements to shift the location of profits to jurisdictions with low effective rates of taxation. Further consultation is also expected on implementing BEPS Action 4 in the banking and insurance sector, which will also be completed during 2016.

(2) If a CbyC effective date is listed and filing date is BLANK, please see the Country Detail tab to determine the first filing deadline.
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B. SUMMARY OF BEPS & ITS ACTION PLANS 3 B. 1. Introduction to BEPS 3 B. 2. Journey of BEPS so far 4 B. 3. Key Points / Highlights for Action Plans 5 B. 4.

7. There is also a December 2015 deadline for some aspects of the interest expense Action Item 4, harmful tax practices (Action Item 5) and the multilateral instrument Action Item 15. OECD, Action Plan on Base Erosion and Profit Shifting (2013).
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On 28 July 2016, the Organisation for Economic Co-operation and Development (“OECD”) issued a discussion draft which deals with approaches to tackle base erosion and profit shifting (“BEPS”) involving interest in the banking and insurance sectors (“the discussion draft”). The common approach to tackling BEPS involving interest In October 2015, the OECD published the final Action 4 2014-09-16 · These BEPS risks will be addressed by the work on the other Actions in the BEPS Action Plan, which will take the relevant features of the digital economy into account. The report also analyses a number of broader tax challenges raised by the digital economy, and discusses potential options to address them, noting the need for further work during 2015 to evaluate these broader challenges and potential options.