On 5 October 2015, the OECD released its final report on the tax challenges of the digital economy (Action 1) under its BEPS Action Plan. 2 The final report indicated that there would be follow-up work carried out in this area and that a supplementary report reflecting the outcomes of continued work on the overall taxation of the digitalization economy would be released by 2020.

An interim report was issued by the OECD in September 2014, setting out the progress made to date on Action 5. Its main focus was on intangible regimes such as patent boxes. Following the report, the UK and Germany put forward proposals endorsing the ‘modified nexus’ approach, which is predicated on a link between the expenditure incurred to develop patents and the income that those

Current concerns are primarily about preferential regimes which can be used for artificial profit shifting and about a lack of transparency in connection with certain rulings. The report sets out an agreed methodology to assess whether there is substantial activity. In the context of IP regimes such as patent boxes, agreement was reached The BEPS Action Plan contains 15 Actions. There is an obligation to implement (minimum standards) with regard to combating harmful tax practices and the spontaneous exchange of information on advance tax rulings (Action 5), the inclusion of abuse clauses in double taxation agreements (Action 6), country-by-country reporting (Action 13) and the dispute resolution mechanisms (Action 14).

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Action 5 Report (OECD, 2015) has been translated into the terms of reference to facilitate the review of an assessed jurisdiction’s compliance with the Action 5 minimum standard. The review will be carried out in accordance with the agreed methodology. This progress report is an update to the 2015 BEPS Action 5 report and contains the results of the review of all Inclusive Framework members' preferential tax regimes that have been identified. The results are reported as at October 2017. One part of the Action 5 minimum standard relates to preferential tax regimes where a peer review is undertaken to identify features of such regimes that can facilitate base erosion and profit shifting, and therefore have the potential to unfairly impact the tax base of other jurisdictions.This progress report is an update to the 2015 BEPS Action 5 report and the 2017 Progress Report. HTP and patent boxes • No consensus in the 2014 progress report but compromise proposal from Germany and the UK maintaining the principle of the nexus approach with some modifications • Nexus approach now been agreed – agreement released on 6 February 2015 • Action 5 requires substantial activities in preferential regimes – initially focused on requiring substantial activities in IP regimes (patent boxes) 14 Chapter 5 of this report provides for a framework for improving transparen­ cy in relation to rulings and introduces a mandatory spontaneous exchange of information on rulings. The Final Report supersedes an initial Progress Report of the FHTP of2014 (hereafter BEPS Action 5 Progress Report).

Persson, Anna. Missbruk av skatteavtal : Kan de föreslagna reglerna i BEPS Subjects/Keywords: BEPS; Action 6; transactions aimed at avoiding tax; treaty However, it is a work in progress, and I believe a European company form  som avses i 4 kap.

Preferential regimes continue to be a key pressure area. Current concerns are primarily about preferential regimes which can be used for artificial profit shifting and about a lack of transparency in connection with certain rulings. The report sets out an agreed methodology to assess whether there is substantial activity. In the context of IP regimes such as patent boxes, agreement was reached

• OECD (2017), Harmful Tax Practices - 2017 Progress Report on Preferential Regimes: Inclusive Framework 3. BEPS Action 5 3.1. nIrot ducotry remarks After around 2005, progress in combating “harmful tax practices” slowed down, and it was not until the wake-up call of the 15-point BEPS Action Plan in 2013 that the Forum picked the thread up again. Action 5 of this Action Plan quite straightforwardly commits the Forum to: OECD BEPS Action Plan: Moving from talk to action in the Americas OECD BEPS Action Plan: Moving from talk to action in the Americas 3 2017 KPMG International Cooperative (KPMG International).

Page 1 of 3 Department for International Tax Cooperation CAYMAN ISLANDS _____ Economic Substance Legislation and Resources

Global actions on. Act Svenska kyrkan och Åsa Thomasson, CONCORD Sverige 5. Inom EU pågår en livlig debatt om hur multi- nationella företags aggressiva skatteflykt, det så kallade BEPS-paketet, sågs som en framgång 2019 Global Progress Report.

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One part of the Action 5 minimum standard relates to preferential tax regimes where a peer review is undertaken to identify features of such regimes that can facilitate base erosion and profit shifting, and therefore have the potential to unfairly impact the tax base of other jurisdictions.This progress report is an update to the 2015 BEPS Action 5 report and the 2017 Progress Report. HTP and patent boxes • No consensus in the 2014 progress report but compromise proposal from Germany and the UK maintaining the principle of the nexus approach with some modifications • Nexus approach now been agreed – agreement released on 6 February 2015 • Action 5 requires substantial activities in preferential regimes – initially focused on requiring substantial activities in IP regimes (patent boxes) 14 Chapter 5 of this report provides for a framework for improving transparen­ cy in relation to rulings and introduces a mandatory spontaneous exchange of information on rulings.

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6 International Migration Report Highlights 2017, 2017, s 4-5 19 BEPS and Developing Countries 2018 Draft Report for Development Partners FOR DISCUSSION 24 28 Annual Report 2018 FAO FLEGT Phase III, p. Global actions on.

Status, Action 7  appropriate action across the entire value chain of deploying low-carbon 5. Deep seabed mining would undermine efforts to reduce material intensity in design Figure 22 OECD estimate of annual ocean value-added output (2010 & 2030). Source: with sufficient powers to report on deep seabed mining processes and  1 The OECD Guidelines for Multinational Enterprises argue that corporations than lending money directly, they act as intermediaries between different groups of clients, Page | 5. Underwriting means that the investment bank buys the securities from the annual report(s) of the financial institution and its subsidiaries. performed global LVP by 5 to 7pp, driven by increased actions are based on observance of ethical standards ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934 profit shifting (“BEPS”) project begun in 2015 with new proposals for a global  Se Sustainovate Progress Report 2018 motsvarande en nettoomsättning på cirka 1,5–2 miljarder kronor i vissa bensindrivna produkt-.

BEPS Action 5 on the compulsory spontaneous exchange of information on tax rulings is intended to provide tax administrations with timely information on rulings that have been granted to a foreign related party of their resident taxpayer or a permanent establishment, which can be used in conducting risk assessments and which, in the absence of exchange, could give rise to BEPS concerns.

The Organisation for Economic Co-operation and Development (OECD) has released the third annual peer review report 1 (the report) relating to the compliance by members of the Inclusive Framework (IF) on Base Erosion and Profit Shifting (BEPS IF 2) with the minimum standard on Action 5 for the compulsory spontaneous exchange of certain tax rulings (the transparency framework). The Action 5 Report, Countering Harmful Tax Practices More Effectively, Taking Into Account Transparency and Substance also provides that additional types of rulings could be added to the scope of the transparency framework in the future, where the FHTP and the Inclusive Framework agree that such a ruling could lead to BEPS concerns in the absence of spontaneous information exchange. 3. BEPS Action 5 3.1. nIrot ducotry remarks After around 2005, progress in combating “harmful tax practices” slowed down, and it was not until the wake-up call of the 15-point BEPS Action Plan in 2013 that the Forum picked the thread up again. Action 5 of this Action … This measure is in response to the Harmful Tax Practices – 2017 Progress Report on Preferential Regimes (Inclusive Framework on Base Erosion and Profit Shifting (BEPS): Action 5) in which Thailand’s regional/international headquarters, trading and treasury hub regimes were … On 5 October 2015, the OECD released its final report on the tax challenges of the digital economy (Action 1) under its BEPS Action Plan.

Since the publication of the 2017 Progress Report (OECD, 2017 [2]) in October 2017, the FHTP has further continued its work on the review of preferential regimes in the scope of BEPS Action 5. One part of the Action 5 minimum standard relates to preferential tax regimes where a peer review is undertaken to identify features of such regimes that can facilitate base erosion and profit shifting, and therefore have the potential to unfairly impact the tax base of other jurisdictions.This progress report is an update to the 2015 BEPS On 5 October 2015, the OECD released its final report on Action 5, Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance (the Action 5 Report) under its BEPS Action Plan.