Papers & Reports

The OECD released a pricing tool and fact sheets to facilitate the understanding and operation of the simplified and streamlined approach to transfer pricing. The fact sheets provide a high-level overview of the mechanics of Amount B, including the steps taxpayers and tax administrations should take to apply Amount B. The Pricing Automation Tool has been developed to automatically compute the Amount B return for an in-scope tested party, requiring only minimal data inputs, and is intended to further optimise the administrative and simplification benefits for both tax administrations and taxpayers.

Under the BEPS Action 5 minimum standard, members of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting have committed to counter harmful tax practices with a focus on improving transparency. This report reflects the outcome of the eighth annual peer review of the implementation of the Action 5 minimum standard.

This article examines the United States' position as the world’s leading tax haven, highlighting its provision of secrecy and low or zero tax rates for nonresident aliens. It discusses how these features align with the defining characteristics of tax havens, making the U.S. a significant player in the global landscape of tax avoidance and financial opacity.

This article explores how the US global intangible low-taxed income (GILTI) regime creates tax asymmetries that influence foreign investment incentives. It provides empirical evidence showing that US multinational enterprises reduce foreign operational risks by consolidating operations in foreign headquarters, particularly in developing countries, as a response to GILTI’s taxation of volatile foreign cash flows. The findings suggest these tax-induced costs do not lead to significant policy benefits, such as reductions in foreign intangible assets. The article’s insights are relevant for potential reforms to GILTI and the implementation of the OECD's global tax framework.

The MAP statistics form part of the BEPS Action 14 Minimum Standard and the wider G20/OECD tax certainty agenda to improve the effectiveness and timeliness of tax-related dispute resolution mechanisms. The statistics provide an objective and global frame of reference, as well as a country-specific view, which together allow measurement of progress but also show where further work is needed.

This article evaluates the new UN framework convention for international tax cooperation, examining its structure, objectives, and potential impact on global tax governance.

This article examines the controversies surrounding the implementation of the OECD's Pillar Two rules in corporate taxation, highlighting their rising prominence on business and political agendas. It frames Pillar Two as a potential flashpoint for international tensions and societal distrust in governance and taxation systems, based on insights shared during a tax practitioners' meeting in Amsterdam on May 30, 2024.

This article addresses the transformative impact of economic digitalization on international tax, focusing on proposed OECD/G20 Inclusive Framework changes that would shift taxing rights across jurisdictions and affect various industries. It examines the implications of these rules for both taxpayers and tax authorities, highlighting how the reallocation of taxing rights might alter the global tax landscape.

This article examines the international tax complexities associated with business profits in the digital economy, focusing on cloud computing services. It analyzes challenges related to the OECD Model Convention (2017), the EU’s proposed Directive on Significant Digital Presence, and the OECD Secretariat's "Unified Approach" under Pillar One. Through these frameworks, the article explores how digital business models, such as cloud computing, present unique issues for profit allocation and taxing rights across jurisdictions.

This article examines the concept of value creation as introduced in the OECD/G20 BEPS Actions, noting its ambiguous and often controversial interpretation that may conflict with existing tax treaties. It discusses the challenges this principle poses for developing coherent international tax policy and for interpreting and applying tax treaties effectively.