Base Erosion and Profit Shifting (BEPS)

• First, international tax rules will be developed to address the gaps between different countries' tax systems, while still respecting the sovereignty of each country to design its own rules.
• Second, the existing rules on tax treaties and transfer pricing will be revisited to fix their deficiencies. This will ensure that profits are taxed in the countries where the economic activities that generate them are carried out.
• Third, more transparency will be established, including through a "country-by-country" reporting by companies to tax administrations on their worldwide allocation of profits. This will be complemented by more transparency between governments, with the need for countries to disclose tax rulings and other tax benefits to their partners.
• Going forward, we will carry out a comprehensive analysis of the economic impact of BEPS, including its effects on taxpayers' behaviour and on public finances, and the macroeconomic implications of BEPS, including international spill-overs.
• Finally, to ensure that the Actions can be implemented faster, a multilateral instrument will be developed for countries that may want to amend the totality of their existing network of bilateral treaties at once, rather than proceed treaty by treaty.

Automatic Exchange of Tax Information

• First, countries from around the world agreed to meet the standard to exchange information on request, including information on bank accounts;
• Second, the Global Forum on Exchange of Information and Transparency for Tax Purposes was restructured to include peer reviews to monitor implementation;
• Third, efforts are now on-going to enhance exchange of tax information: 120 jurisdictions are exchanging tax information on request, based on more than 1100 agreements signed in the last few years. Four years ago, there were only 40. We are pleased with these developments, but there is no room for complacency;
• Fourth, the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, originally signed between the Council of Europe and the OECD, was aligned to the international standard and opened to all countries.

Moving towards a higher standard

• In April, five European countries announced their intention to exchange FATCA (Fair and Accurate Credit Transactions Act)-type information with each other and with the United States. This approach was subsequently joined by other countries, both in Europe and beyond;
• In May, the European Council called for priority to be given to automatic exchange and welcomed the on-going efforts made in the G8, the G20 and the OECD to develop a global standard;
• Last June, in Loch Erne, I presented a report to the G8 leaders on how to deliver an effective system for automatic exchange of information in the multilateral context and the G8 leaders resolved to establish automatic exchange as the new global standard;
• Also last June, the European Commission adopted a legislative proposal to extend the Mutual Assistance Directive to dividends, capital gains, account balances, among others;
• And in July, the G20 Finance Ministers endorsed a new, single, global standard for automatic exchange of tax information and mandated the OECD to complete it by 2014. This was further endorsed by G20 Leaders, including the President of the European Commission and the President of the European Council, at the G20 Summit in Saint Petersburg last week

Putting words into action

Bron: OECD