(January 2, 2015) 

2015 has just started and with the OECD instead of sending Holiday wishes issuing several Discussion Drafts right before Christmas, we felt it might be a good idea to make an inventory of which BEPS Discussion Drafts were recently issued and are still open for comments. 

In the sub-section “Base Erosion and Profit Shifting (BEPS)” of our section “OECD & Model Conventions” you will find a VERY EASY ACCESSIBLE overview of all BEPS Discussion Drafts issued so far by the OECD. The overview is organized based on the ACTION of the BEPS Action Plan they relate to.

·       Public Discussion Draft: Follow-up work on BEPS Action 6: Preventing Treaty Abuse (Written comments have to be submitted by January 9, 2015);

·       Public Discussion Draft – BEPS Action 7: Preventing the Artificial Avoidance of PE Status (Written comments have to be submitted by January 9, 2015);

·       Public Discussion Draft – BEPS Action 10: Proposed Modifications to Chapter VII of the Transfer Pricing Guidelines Relating to Low Value-Adding Intra-Group Services (Written comments have to be submitted by January 14, 2015);

·       Public Discussion Draft – BEPS ACTION 14: MAKE DISPUTE RESOLUTION MECHANISMS MORE EFFECTIVE (Written comments have to be submitted by January 16, 2015);

·       Public Discussion Draft – BEPS ACTION 10: DISCUSSION DRAFT ON THE TRANSFER PRICING ASPECTS OF CROSS-BORDER COMMODITY TRANSACTIONS (Written comments have to be submitted by February 6, 2015);

·       Public Discussion Draft – BEPS ACTION 10: DISCUSSION DRAFT ON THE USE OF PROFIT SPLITS IN THE CONTEXT OF GLOBAL VALUE CHAINS (Written comments have to be submitted by February 6, 2015)

·       Public Discussion Draft – BEPS ACTION 4: INTEREST DEDUCTIONS AND OTHER FINANCIAL PAYMENTS (Written comments have to be submitted by February 6, 2015);

·       Public Discussion Draft – BEPS ACTIONS 8, 9, 10: DISCUSSION DRAFT ON REVISIONS TO CHAPTER I OF THE TRANSFER PRICING GUIDELINES (INCLUDING RISK, RECHARACTERISATION, AND SPECIAL MEASURES (Written comments have to be submitted by February 6, 2015);

Although the following Discussion Draft(s) are not BEPS Discussions Drafts, we feel they are important enough to be included in this overview.

·       Discussion Drafts for Public Consultation – INTERNATIONAL VAT/GST GUIDELINES

o      GUIDELINES ON PLACE OF TAXATION FOR BUSINESS-TO-CONSUMER SUPPLIES OF SERVICES AND INTANGIBLES

o      PROVISIONS ON SUPPORTING THE GUIDELINES IN PRACTICE

(Written comments have to be submitted by February 20, 2015)

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