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——————————————— CONTACTS. For additional information with respect to this Alert, please contact the following: Ernst & Young Belastingadviseurs LLP, Rotterdam How BEPS 2.0 unified approach will revolutionize business models By Sophie Boulanger in Tax , 21.10.2019 With its new proposal (published October 9), the OECD tries to answer one burning question: BEPS 2.0 — Part 2: Pillar One The first part in this series looked at the OECD’s work in relation to BEPS 1.0 and introduced the subsequent work undertaken by the Inclusive Framework under BEPS 2.0, specifically the Pillar One and Pillar Two proposals. “BEPS 2.0” describes the continuation of work in this space. Further announcements in respect of BEPS 2.0 are now expected in October 2020.

The BEPS Report, taken together with BEPS Actions 7 and 13, can lead tax authorities to challenge this particular model, particularly when seeing very high top-line revenues, very low people count, and relatively modest in-country profit margins. As a result, in the post-BEPS world, petrochemical companies may want to pay To counter tax treaty abuse, the BEPS project has laid down minimum standards, involving a limitation on benefits [LOB] rule and/or a principal purposes test. [PPT] The U.S. LOB rules are currently undergoing a public consultation and the OECD will await its outcome in considering its impact on Action 6. The PPT is similar in.

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on people functions in spite of the economic reality that capital and returns to capital . often play a more critical role in business success or failure.

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BEPS Action 1 21 Jan 2020 Building on the Organisation for Economic Cooperation and Development's ( OECD) Base Erosion and Profit Shifting (BEPS) initiative, the Pillar 2 30 Jan 2020 FAQ on Digital Services Taxes and the OECD's BEPS Project the scope of the project has expanded, now also referred to as “BEPS 2.0.

On 12 October 2020, the Organisation for Economic Co-operation and Development (OECD) and the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) released a series of documents in connection with the ongoing project on addressing the tax challenges arising from the digitalization of the economy (the "BEPS 2.0 project"). November 11, 2019 | KPMG's Steve Blough outlines the focus of BEPS 2.0 and the measures the OECD is considering to address related issues. [3:14 minutes] OECD releases BEPS 2.0 Pillar Two Blueprint and invites public comments Executive summary On 12 October 2020, the Organisation for Economic Co-operation and Development (OECD) released a series of major documents in connection with the ongoing G20/OECD project titled “Addressing the Tax Challenges of the Digitalisation of the Economy” (the BEPS 2.0 project). The blueprints for Pillars One and Two of BEPS 2.0 published in October 2020 expose an inherent policy conflict between the original policy strands of BEPS 1.0, as well as create other basic policy tensions in the international tax system.
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As a result, in the post-BEPS world, petrochemical companies may want to pay To counter tax treaty abuse, the BEPS project has laid down minimum standards, involving a limitation on benefits [LOB] rule and/or a principal purposes test. [PPT] The U.S. LOB rules are currently undergoing a public consultation and the OECD will await its outcome in considering its impact on Action 6. The PPT is similar in. Tax and Digitalisation.

The OECD’s Base Erosion and Profit Shifting Project (BEPS) aims to secure and sustain the international tax system and increase tax equity among traditional and digital businesses. Since our last post on BEPS 2.0 (published in February 2020) and despite the COVID-19 situation, the OECD has dedicated further resources and made significant progress on this topic as described by the OECD in their "Update on the Programme of Work since February 2020", included in the OECD’s Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors report published in July 2020.
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Gezien de BEPS - план действий в области международного налогообложения, id. com/2016/presentation-research/presentations/EconomicaRunetaItogy2016.pdf. 191 Миловидов В.Д. Корпоративное управление 2.0: эволюция системы With the possible incorporation of the simplified LOB rule and the PPT into the. Hong Kong tax treaties, financial services groups (including private equity funds) The OECD G20 Base Erosion and Profit Shifting Project (or BEPS Project) is an OECD/G20 project to set up an international framework to combat tax avoidance 28 Feb 2019 Luxembourg Ratifies the BEPS Multilateral Instrument However, the OECD itself has provided examples where the PPT test may be satisfied PPT – Principal Purpose Test 2.1.2. O papel da OCDE no desenvolvimento da política fiscal.