BEPS Action 12: Mandatory disclosure rules Response by the Chartered Institute of Taxation 1 Introduction 1.1 The Chartered Institute of Taxation (CIOT) is pleased to respond to the Public discussion draft published on 31 March 2015 on BEPS Action 12: Mandatory disclosure rules (Discussion Draft).

10 Sep 2019 certain notions such as the main benefit test, the commentaries of the bill of law explicitly refer to the BEPS Action 12 Final Report. In the latter

2.2 Action 6 – Preventing the Granting of Treaty Benefits in Inappropriate tänkt att fungera tillsammans med ett Principal Purpose Test (PPT) som bedömer Action 11 – Measuring and Monitoring BEPS. 19. Action 12 – Require Taxpayers to Disclose their Aggressive Tax Planning Arrangements. 19.

BEPS Action Plan: Action 8 - Transfer pricing and intangibles. BEPS Action Plan: Action 9 - Transfer pricing and risks/ capital. BEPS Action Plan: Action 10 - Transfer pricing and other high-risk transactions. BEPS Action Plan: Action 11 - Data and methodologies.

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OECD Action Plan on BEPS (cont’d) " Action Items 6-10: Restoring the full effects and benefits of international standards; aligning taxation with substance 6. Prevent treaty abuse. April 2014 draft report. Clarify model treaty rules to ensure no double non-taxation. Coordinate with work on hybrids. Strengthen LOB (limitation on benefits

This is an anti-abuse rule designed to avoid treaty shopping by agents, nominees or conduit companies for the benefit of a resident of a third state. Where dividends, interest or royalties deriving from a Contracting State are paid to a resident of the other Action to fight corporate tax avoidance has been deemed necessary in the OECD forum has and received further impetus through the G20/OECD Base e rosion and p rofit shifting action plan (known as BEPS). The BEPS action plan has 15 actions, covering eleme2015 - nts used in corporate tax avoidance practices and aggressive tax-planning schemes.

• OECD’s BEPS Action Plans - a project developed by OECD / G20 Member Countries - 12 June 2019) MLI Notified by Ministry of Finance. 9 August 2019. • Targets abusive arrangements entered into with the main purpose of obtaining a tax benefit. GAAR. Impact. Denial of tax benefit or benefit …

[ vii] OECD, Mandatory Disclosure Rules, Action 12 – 2015 Final 10 Jan 2020 However, in identifying the main benefit of an insurance solution, clients resemble the recommendations of the BEPS Action 12 Final Report (the Final some of which apply only where the main benefit test (MBT) is me This will be the case if obtaining a tax advantage is the main benefit, or one of DAC6 includes a few significant differences compared to the BEPS Action 12 2 May 2019 This is partly in response to the OECD BEPS Action 12 (mandatory Although some of hallmarks have a "main benefit" test which will be met if 16 dec 2019 OECD (2015) BEPS Action 12 Report. Framework, design principles (A) Algemene wezenskenmerken met main benefit test. (B) Specifieke 5 Dec 2019 [6]The GAAR introduced the OECD principal-purpose test and was Granting of Treaty Benefits in Inappropriate Circumstances – Action 6: 2015 Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against&n 10 May 2019 Action 12 of the OECD's BEPS project sets out key recommendations in the form of the principal purpose test or a limitation of benefits clause. 10 May 2015 They have not been aimed mainly at international tax avoidance techniques, nor indeed at corporate tax avoidance. Their main focus in most 4 Jul 2019 project on Base Erosion and Profit Shifting (BEPS) that the OECD launched in 2015. Certain hallmarks can only be considered if a main benefit test is also Considering the above, insurers must take necessary acti DAC6 broadly reflects OECD's recommendations in BEPS Action 12.

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Introduction 1.1 The OECD's Base Erosion and Profit Shifting (BEPS) project is nearing its conclusion.
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As part of BEPS countermeasures, the main challenge faced by Action 12 is thought to be how to apply the recommendations to international tax schemes. However, the criteria for application leave room for broader interpretation by each nation, raising serious concerns about a possible undue increase in the volume of information to be disclosed by taxpayers.

Europaparlamentet välkomnar kommissionens antagande den 12 april 2016 av ett Measuring and Monitoring BEPS, Action 11 - 2015 Final Report, OECD/G20 Base to outperform every major indicator and restore its current account balance. regarding 'beneficial ownership', there should be a test to check who is the Base Erosion Profit Shifting (BEPS) – vad händer nu? När arbetet inleddes med rapporten Addressing BEPS och den påföljande BEPS Action Plan 2013.