The OECD report [PDF 940 KB] provides an update of the base erosion and profit shifting (BEPS) project and tax transparency, among other information. With respect to the BEPS status update, there are 95 member countries and 19 countries that “are likely to join” by year-end. It is further reported that progress towards BEPS implementation is underway, with over 50 countries having taken “concrete steps” to implement country-by-country reporting.
The next steps include the completion of negotiations by 96 countries on tax treaty-related BEPS actions being incorporated in the multilateral instrument on BEPS implementation.
This multilateral instrument would allow countries to meet the BEPS minimum standard aimed at ending treaty shopping, to address hybrid mismatches to update the definition of “permanent establishment,” and to address other forms of treaty abuse with specific treaty rules and improving dispute resolution processes. It is anticipated that given the participants in the negotiations, more than 2,000 bilateral tax treaties could be amended if the 96 countries sign the convention once the instrument is finalized.
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