BEPS

TEI Comments on Canadian Budget Consultation on Tax Planning by MNEs (BEPS)

On June 11, 2014, Tax Executives Institute submitted comments on the Consultation on Tax Planning by Multinational Enterprises announced in Annex 2 of the 2014 Canadian Budget Message.

TEI Comments on BEPS Action 2: Hybrid Mismatch Arrangements

On May 1, 2014, TEI submitted comments to the OECD regarding its Public Discussion Drafts on BEPS Action 2: Neutralise the Effects of Hybrid Mismatch Arrangements (Recommendations for Domestic Laws and Treaty Issues). TEI’s comments focused on the need for the OECD to specifically delineate the instruments and transactions that would be subject to the proposed, the proposed rules intended effect, and to coordinate the rules’ implementation across jurisdictions to prevent double-taxation from arising. 

TEI Comments on OECD BEPS Action 1: Digital Economy

On April 13, 2014, TEI submitted comments to the OECD regarding its Public Discussion Draft on BEPS Action 1:  Address the Tax Challenges of the Digital Economy. The Institute agreed with the OECD that there was no need to “ring fence” the digital economy through the adoption of special or separate international tax rules, and that any such attempt would be inadvisable.

TEI Comments on OECD BEPS Action 6: Prevent Treaty Abuse

On April 8, 2014, TEI submitted comments to the OECD regarding its Public Discussion Draft on BEPS Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances. The Institute’s comments generally focused on the need for objective rules if the OECD is to combat inappropriate “treaty shopping.” TEI recommended that such rules should be in the form of clearly defined “limitation-on-benefits” provisions in the OECD’s Model Tax Convention, and not in the form of a general anti-abuse rule.

TEI Submits Further Comments on OECD BEPS Action Plan

On October 16, 2013, TEI submitted a second letter to the OECD commenting on the OECD’s Action Plan on Base Erosion and Profit Shifting.  TEI’s comments addressed issues under the 15 individual items of the Action Plan, including transfer pricing aspects of intangible assets, changes to the OECD model treaty, and improvements to the mutual agreement procedure. 

The comments were prepared under the aegis of TEI’s European Direct Tax Committee, whose chair is Alexander Kölbl of General Dynamics.  Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI’s letter. 

TEI Comments on OECD BEPS Action Plan

On September 18, 2013, TEI submitted a letter to the OECD commenting on its Action Plan on Base Erosion and Profit Shifting. TEI's comments focused on the general principles of the current international tax system and the need for the OECD maintain those principles as it advances its Action Plan to combat perceived base erosion and profit shifting by multi-national enterprises.

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