BEPS Corner

Action 1

On March 16th, the OECD published an interim report on the digitalization of the economy. The report is mainly an inventory of the situation, without any concrete proposal for the evolution of the digital tax system, illustrating the difficulty that countries have to reach a consensus on this subject. A final report is planned for 2020, but is likely to have difficulty to emerge, so far the positions are today ().  

Action 5

On January 24th, 2018, as part of the 2017 Progress Report on Preferential Regimes, the Inclusive Framework on BEPS approved updates to the results of preferential tax regimes as a result of compliance efforts made by some States. Indeed, Barbados announced changes to the “International Financial Services” and “Foreign Currency Revenues credits/Credit for Projects or Services Abroad” regimes and Canada confirmed the abolition of the “International Banking Centers” regime.

Action 7

Publication on March 22th, of a complementary report on the attribution of profits to permanent establishments. The document details several examples, related to warehouse management cases in the context of a digital transaction, Internet advertising or distribution through a broker.

Action 13

On February 8th, 2018, the OECD published a new version of the CbCR implementation guidelines. This version adds details on the following two subjects: the definition of the group’s total consolidated turnover and the consequences of non-compliance with the conditions of confidentiality and appropriate use of data by administrations. The consolidated version of these instructions is available on the OECD website .