BEPS: KPMG comment letters on Actions 3 and 12

BEPS: KPMG comment letters on Actions 3 and 12

The Organisation for Economic Co-operation and Development (OECD) in early April 2015 released two discussion drafts, one under Action 3 and the other under Action 12 of the base erosion and profit shifting (BEPS) project.

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  • The discussion draft [PDF 576 KB] under BEPS Action 3 (strengthening CFC rules) focuses on developing recommendations for the design of controlled foreign company (CFC) rules to combat base erosion and profit shifting and considers all the constituent elements of CFC rules and breaks them down into the “building blocks” that are necessary for effective CFC rules.
  • The discussion draft [PDF 668 KB] under BEPS Action 12 (mandatory disclosure rules) is intended to address the challenge tax authorities face in obtaining information on potentially aggressive or abusive tax avoidance arrangements (ATAs) by requiring taxpayers and their advisers to disclose information about ATAs.

KPMG has submitted to the OECD written comments concerning both discussion drafts.

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