Base erosion and profit shifting: Treaty aspects
Source: The Tax Specialist Journal Article
Published Date: 1 Apr 2014
The OECD has concerns that bilateral tax treaties often fail to prevent double non-taxation that results from interactions among more than two countries. The OECD’s base erosion and profit shifting (BEPS) project is intended to address these concerns. The project relates to instances where the interaction of different tax rules leads to double non-taxation or less than single taxation, and to arrangements that achieve no or low taxation by shifting profits away from the jurisdictions where the activities creating those profits take place.
This article discusses the tax treaty aspects of the BEPS project. It focuses on the OECD’s concerns regarding tax treaty abuse and avoidance of permanent establishment status, including the sources of those concerns and the changes that the OECD might recommend to address them. The article also briefly discusses transparency, dispute resolution and the potential use of a multilateral agreement to implement some of the recommendations of the project.
Sorry, this is subscriber only content.
To gain access to this material and much more - Subscribe Now.
(Note: Members can access Taxation in Australia journal articles without a Tax Knowledge Exchange subscription - please log in to access).
Already a Subscriber? Login now
Already a Subscriber? Login now
Details
- Published By: Claudio Cimetta
- Published On:1 Apr 2014
The material is copyright. Apart any fair dealing for the purpose of private study, research criticism or review, as permitted under the copyright Act, no part may be reproduced by any process without written permission from The Tax Institute.
Unless expressly stated, opinions are not that of The Tax Institute, which accepts no responsibility for the accuracy of any of the information contained within it.
The Tax Institute
(ABN 45 008 392 372 (PRV14016))
("TTI")
The Tax Institute is a Recognised Tax Agent Association (RTAA) under the Tax Agent Services Regulations 2009.
Copyright Statement
All materials provided on this site are protected by copyright and are owned by or licensed to TTI.
Except as expressly permitted by TTI or the copyright owner, any person or company who uses this site must not use, reproduce, redistribute, retransmit, publish or otherwise transfer, or commercially exploit, the materials or any information, software or other content, in whole or in part, which is available through this site.
Tags
Share this page