Formally, the OECD clarifications concerning COVID-19 are not binding on tax administrations. The document lays out several concepts that will impact which companies are affected and how much they will need to pay. The public consultation on the OECD Secretariat’s proposed “Unified Approach” to international corporate taxation ends on November 12th. 0000044915 00000 n A vast network of tax treaties to facilitate investment When comparing countries’ foreign direct investment, you would expect the world’s largest economies to top the list. << /S 148 /I 305 /Filter /FlateDecode /Length 284 >> Under Pillar Two of the Programme of Work, members of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) agreed to explore, on a without prejudice basis, issues and design options in connection with the development of a co-ordinated set of rules: These rules would be implemented by way of changes to domestic law and tax treaties and would incorporate a co-ordination or ordering rule to avoid the risk of double taxation that might otherwise arise where more than one jurisdiction sought to apply these rules to the same structure or arrangement. If a company’s executive bodies perform their activities in Russia in a volume which is ‘significantly less’ than in other countries, then Russia is not treated as the place of management of the entity in question (article 246.2 of the Russian Tax Code). This consultation document has been prepared by the Secretariat, and do not represent the consensus views of the Inclusive Framework, the Committee on Fiscal Affairs, or their subsidiary bodies. To that end, I have three suggestions for the OECD: For more on these issues, please see my new paper “A New Global Tax Deal for the Digital Age.”. A public consultation meeting on the GloBE proposal will be held on 9 December 2019, at the OECD Boulogne in Boulogne-Billancourt. 0000009987 00000 n 0000005744 00000 n %PDF-1.4 0000001849 00000 n Further information about attending the public consultation is available on the dedicated meeting page. This consultation document requests input from stakeholders on their experience with, and views on, carve-outs and thresholds that may be considered as part of the GloBE proposal. Be more forthcoming about how it goes about choosing experts to act on behalf of the Secretariat and how the Secretariat decides what is feasible, whether in the BEPS project or otherwise. In most cases, this is the place where the person was working prior to the COVID-19 crisis.