Third meeting of the Inclusive Framework on BEPS delivers results

Over 200 delegates from 83 countries and jurisdictions as well as 12 international and regional organisations met in Noordvijk, The Netherlands for the Third Meeting of the Inclusive Framework on Base Erosion and Profit Shifting (BEPS), reports OECD.org.

The meeting welcomed Viet Nam as its newest and 100th member and discussed and approved its first monitoring report, which will be submitted to G20 Leaders for their summit to be held on 7-8 July 2017 in Hamburg. The report highlights the progress that has been achieved since the Inclusive Framework first met in Kyoto in June 2016. The meeting also approved the release of discussion drafts on Attribution of Profits to Permanent Establishments and Transactional Profit Splits.

 Furthermore, as part of continuing efforts to boost transparency by multinational enterprises (MNEs), Belize, the Cayman Islands, Colombia, Haiti, Pakistan, Singapore and the Turks and Caicos Islands signed the Multilateral Competent Authority Agreement for Country-by-Country Reporting (CbC MCAA), bringing the total number of signatories to 64.

 The CbC MCAA is an efficient mechanism that allows signatories to bilaterally and automatically exchange Country-by-Country Reports with each other, as contemplated by Action 13 of the BEPS Action Plan. It will help ensure that tax administrations obtain a better understanding of how MNEs structure their operations, while also ensuring that the confidentiality and appropriate use of such information is safeguarded. At present, over 800 bilateral exchange relationships have been put in place for the exchange of Country-by-Country Reports.

At the same time, the United States concluded a further set of bilateral competent authority arrangements for the automatic exchange of Country-by-Country Reports. It now has arrangements in place with Canada, Denmark, Guernsey, Iceland, Ireland, Korea, Latvia, the Netherlands, New Zealand, Norway, the Slovak Republic and South Africa, thereby reaffirming the strong commitment of the United States to start the automatic exchange of Country-by-Country Reports in 2018. The United States Competent Authority continues to negotiate with a significant number of jurisdictions and anticipates concluding additional competent authority arrangements in the immediate future.

At the signing ceremony, Singapore also signed the Multilateral Competent Authority Agreement for the Common Reporting Standard‎ (CRS MCAA), re-confirming its commitment to implementing the automatic exchange of financial account information pursuant to the OECD/G20 Common Reporting Standard (CRS) in time to commence exchanges in 2018. Singapore is the 92nd jurisdiction to sign the CRS MCAA.

The meeting also discussed the toolkits under development by the Platform for Collaboration on Tax, including the toolkit on Comparables released today.


Finally, the meeting also included a special session with representatives from TUAC, the BIAC Tax Committee, and civil society.

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