OCSE e G20 stanno preparando un'offensiva che molti stanno sottovalutando.
Introduction
Addressing base erosion and profit shifting (BEPS) is a key priority of governments around the globe. OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. Beyond securing revenues by realigning taxation with economic activities and value creation, the OECD/G20 BEPS Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. A key focus of this work is to eliminate double non-taxation. However in doing so, new rules should not result in double taxation, unwarranted compliance burdens or restrictions to legitimate cross-border activity.
This document contains the first set of reports and recommendations to address seven of the actions in the BEPS Action Plan published in July 2013. Given the Action Plan’s aim of providing comprehensive and coherent solutions to BEPS, the proposed measures, while agreed, are not yet formally finalised as they may be impacted by some of the decisions taken with respect to the 2015 deliverables with which they interact. They do reflect consensus on a number of solutions to put an end to BEPS.
With the adoption of this first set of deliverables and the implementation of the relevant measures by national governments, hybrid mismatches will be neutralised; treaty shopping and other forms of treaty abuse will be addressed; abuse of transfer pricing rules in the key area of intangibles will be greatly minimised; country-by-country reporting will provide governments with information on the global allocation of the profits, economic activity and taxes of multinational enterprises (MNEs).
Equally, OECD and G20 countries have agreed a report concluding it is feasible to implement BEPS measures through a multilateral instrument. They have also advanced the work to fight harmful tax practices, in particular in the area of IP regimes and tax rulings. Finally, they have reached a common understanding of the challenges raised by the digital economy, which will now allow them to deepen their work in this area where BEPS is exacerbated.
BEPS by its nature requires coordinated responses, particularly in the area of domestic law measures. This is why countries are investing time and resources on developing shared solutions to common problems. At the same time, countries retain their sovereignty over tax matters and measures may be implemented in different manners, as long as they do not conflict with their international legal commitments.




Rispondi Citando


