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1
Mączyński, Dominik. "The BEPS Influence on Tax Information Exchange." Studia Iuridica Lublinensia 27, no. 2 (September 17, 2018): 127. http://dx.doi.org/10.17951/sil.2018.27.2.127.
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Choi, Seong-Keun. "A Study on OECD BEPS Project and the Legislation to Regulate the Tax Avoidance of Multinational Enterprises." Han Yang Law Review 29, no. 2 (May 31, 2018): 55–92. http://dx.doi.org/10.35227/hylr.2018.05.29.2.55.
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Abu Bakar, Ahmad Ridzuan, Ahmad Tarmizi Haron, and Rahimi A. Rahman. "Building Information Modelling Execution Plan (BEP): A Comparison of Global Practice." International Journal of Engineering Technology and Sciences 7, no. 2 (September 17, 2021): 63–73. http://dx.doi.org/10.15282/ijets.7.2.2020.1005.
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Building Information Modelling (BIM) is a process supported by technologies involving the development and management of 3D digital information model representations of functional and physical of the design. To implement BIM in a project, BIM Implementation Plan or BIM Execution Plan (BEP) needs to be developed as a planning and monitoring strategy document. Several BEPs have been developed around the world since 2010. However, a BEP should be tailored to the type of project, stakeholder requirement, and project objectives because a comprehensive BEP is a key factor for BIM implementation success. Also, a proper BEP helps stakeholders understand and achieve the underlying objectives in using BIM. In other words, understanding the strategic framework of BEPs is important. Hence, this study identifies and compares the key elements in existing BEPs. To accomplish that aim, twenty BEPs were identified and analysed. This study provides a benchmarked reference for industry players on existing BEPs. Through a clear description, all parties can understand the project objectives, work process, roles and responsibilities, information need and deliverables requirements in a BEP. Researchers can use the findings for further development and improvement of existing BEPs. Understanding BEPs will ensure better BIM implementation in practice.
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Капустина, Лариса, Larisa Kapustina, Н. Портнов, and N. Portnov. "Review and appraisal of the implementation of OECD initiatives, "the erosion of the tax base and the withdrawal of profits from taxation"." Russian Journal of Management 4, no. 3 (November 2, 2016): 266–70. http://dx.doi.org/10.12737/21953.
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The article describes the key provisions of OECD Base Erosion and Profit Shifting (BEPS) project. The article describes necessities for creation of BEPS. Author analyses possible difficulties of application of BEPS as well as consequences of implementation and possible impact on investment climate of BEPS.
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Rosdina, Haula. "Country Note: Review of Implementation of the Inclusive Framework on Base Erosion and Profit Shifting in Indonesia." Intertax 47, Issue 6/7 (July 1, 2019): 635–51. http://dx.doi.org/10.54648/taxi2019062.
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Tax avoidance by multinational enterprises in Indonesia has led to a massive, ongoing loss of tax revenue. A type of tax avoidance known as base erosion and profit shifting (BEPS) has become a global issue and compelled the OECD to take measures by releasing the BEPS Action Plan and launching the BEPS Project. Indonesia declared its commitment to adopt appropriate parts of the outcome of the BEPS Project for developing countries in Indonesia’s domestic tax rules, recognized as the Inclusive Framework on BEPS or BEPS Minimum Standards. This article analyses the implementation of the BEPS Minimum Standards in Indonesia and how the government has taken action to counteract tax base erosion. The author considers qualitative research and data collected through a literature study and in-depth interviews. Indonesia is in the process of implementing the BEPS Minimum Standards, as addressing transfer pricing issues and preventing tax treaty abuse are currently particular areas of focus for the government.
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Mightyn, Alfa, and Arifah Fibri Andriani. "ANALISIS PENERAPAN CONTROLLED FOREIGN COMPANY RULES DALAM MENGATASI BASE EROSION AND PROFIT SHIFTING DI INDONESIA." INFO ARTHA 3 (May 23, 2017): 1–14. http://dx.doi.org/10.31092/jia.v3i0.53.
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One cause for the inability to achieve the expected tax revenue target for some last years was the practice of tax avoidance. One form of tax avoidance is the utilization of Controlled Foreign Company (CFC) to defer the recognition of income from overseas over WPDN capital to be taxed in the country. This practice is also faced by many other countries in the world. The issue of the Base Erosion and Profit Shifting (BEPS) has been of concern to developed and developing countries. G20 countries cooperate with OECD to form a BEPS Project to formulate measures to address these BEPS. Indonesia as one of the Associate Members of the Project BEPS has a position that is parallel to the other OECD countries and participates in implementing the BEPS results. BEPS Project has resulted in BEPS Action Plans which one of them is Action 3: Strengthening CFC Rules. Action 3 will provide recommendations to the domestic law related to the design of CFC Rules. Until now, related to Action 3, BEPS Project has issued a Public Discussion Draft Action 3: Strengthening CFC Rules. This draft is divided into seven "building blocks" required for CFC Rules to be effective. The aim of this study is to analyze the effectiveness of CFC Rules in Indonesia, whether it is sufficient to prevent BEPS. After that, we can determine what steps should be taken by Indonesian tax authorities to strengthen the CFC Rules in Indonesia based on seven dimensions of building blocks. The conclusions of this study are (1) CFC Rules in Indonesia as a whole have not been able to overcome BEPS; and (2) When compared with the recommendations of the Discussion Draft Action Plan 3, CFC Rules Indonesia needs to be improved. However, the necessary improvements should be adjusted to match the needs and characteristics of Indonesia.
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Леонова, Ольга, and Olga Leonova. "VALUE OF PROJECT BEPS AND EU LAW: LIMITATION OF THE USE OF TAX TREATY BENEFITS." Journal of Foreign Legislation and Comparative Law 2, no. 1 (March 16, 2016): 0. http://dx.doi.org/10.12737/18188.
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This article is devoted to legal relations arising from application of international tax treaties. The subject matter of this article is the norms of international and European Law and also soft law designed for preventing treaty abuse. The author considers Article 22 of the Model US Tax Convention. According to the current recommendations of OECD in the framework of BEPS Project regarding preventing the granting of treaty benefits in inappropriate circumstances, this provision should be considered as legal base for including in the Model OECD Tax Convention. The author focuses on the issue whether the provision regarding limitation of treaty benefits is consistent with EU law and the established practice of the European Court of Justice. The methodological foundation of this article includes general and specific approaches of scientific knowledge. During preparation of this article the author used methods of legal, structural, comparative and linguistic analysis. Moreover, the author applied the technical method for analysis of texts and wordings of model international conventions and international tax treaties. The author analyzed the provision of the Model US Convention regarding limitation of treaty benefits, because it is expected to be included in all international treaties, including in treaties of EU member states in the framework of BEPS Project, elaborated by the OECD.
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Ahmed, Muhammad Ashfaq. "Pakistan: Bracing for BEPS." Intertax 48, Issue 3 (March 1, 2020): 329–45. http://dx.doi.org/10.54648/taxi2020029.
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The article spatially juxtaposes the BEPS Project and the recommendations package handed down thereunder in Pakistan and critically appraises its response at two levels: ideational and practical. It is argued that the ideational lens of sovereignty, efficacy, and legitimacy through which the BEPS phenomenon and its outcomes are being keenly looked at elsewhere has not really spiced Pakistan’s response to the Base Erosion and Profit Shifting (BEPS) proposals or the public policy debate surrounding them. At the practical level, it critically maps the BEPS-specified areas that Pakistan has already chartered and those that remain unchartered. The ideational level strings obliquely steer the debate at the practical level. Pakistan & BEPS, BEPS and Sovereignty, BEPS and Legitimacy, BEPS Implementation, International Tax Reform.
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Hlushchenko, Yaroslava, Olena Korohodova, Natalya Chernenko, and Kateryna Moskvychova. "THE IMPACT OF THE TAX LANDSCAPE OF THE COUNTRY ON THE TAX PLANNING OF TNCs UNDER THE BEPS PROJECT." Academic Review 1, no. 60 (January 2024): 93–104. http://dx.doi.org/10.32342/2074-5354-2024-1-60-7.
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The article notes that in the context of globalization, multinational corporations exert an increasing influence on the economies of their home countries, host countries, and the overall state of international economic relations. The authors underline that tax planning is one of the TNC activities that grabs attention of the global public in terms of both its favorable and unfavorable effects. The article offers its own definition of the term «tax landscape», in which, unlike the existing ones, vertical, horizontal and temporal aspects are distinguished. The vertical aspect is presented as a synthesis of the supranational level of taxation and the national one; horizontal, as a system of tax rules and laws within a separate state; temporal, as a change in the main elements of taxation over time. It has been proven that at the current stage of formation of tax landscapes to characterize the supranational level, it is necessary to take into account the elements of taxation defined as part of the implementation of the international BEPS project: the global minimum tax, tax rates for surplus profits, and surplus profits as an object of taxation. The authors have been able to divide the studied countries into three groups depending on the level of direct taxation: high (United States, Canada and Australia), moderate (Great Britain, France, Italy, India, Germany and Switzerland), and low (China and Saudi Arabia). The first group (the United States) and the second group (the United Kingdom, Germany, France, Switzerland, and Italy) have been found to have the greatest tax losses as a result of «tax havens.» The level of direct taxation (profit and capital) in the countries of registration and countries of digital presence, the volatility of tax legislation, and compliance with the conditions of tax justice have been proposed as factors of the tax landscape to be taken into account by transnational corporations when developing tax planning strategies.
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de Abreu Cunha, Ariel. "Planejamento Tributário Internacional no Projeto BEPS: Agressivo ou Agredido?" Revista de Direito Tributário Internacional Atual 5, no. 5 (2019): 67. http://dx.doi.org/10.46801/2595-7155-rdtia-n5-4.
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Baker, Philip. "The BEPS Project: Disclosure of Aggressive Tax Planning Schemes." Intertax 43, Issue 1 (January 1, 2015): 85–90. http://dx.doi.org/10.54648/taxi2015007.
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Action 12 of the Base Erosion and Profit Shifting (BEPS) Action Plan promises the development of new rules on disclosure of aggressive tax planning arrangements. This article examines the meaning of the phrase, the experience of the UK with Disclosure of Tax Avoidance Schemes, and raises some issues about the Organization for Economic Cooperation and Development (OECD) plans in this area.
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Baker, Philip. "Editorial: The BEPS 2.0 Project Over the Coming Months." Intertax 48, Issue 10 (September 1, 2020): 844–47. http://dx.doi.org/10.54648/taxi2020085.
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Bendini, Juliana Do Nascimento, Michelli Ferreira Dos Santos, Maria Carolina De Abreu, Gardner Andrade Arrais, Maria Mayara Vieira, Wllamo Pacheco Coelho-Junior, and Vanessa Alves Lima. "Meliponário didático: a extensão universitária como uma estratégia para a conservação das abelhas sem ferrão no semiárido piauiense." Revista Brasileira de Extensão Universitária 11, no. 3 (September 4, 2020): 277–88. http://dx.doi.org/10.36661/2358-0399.2020v11i3.11554.
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Considerando a educação ambiental como instrumento de transformação e uma prioridade entre as ações rumo ao desenvolvimento sustentável, o projeto de extensão universitária “Meliponário didático: uma estratégia para a conservação das abelhas sem ferrão no semiárido piauiense” visa a sensibilização de crianças e jovens, estudantes da educação básica do município de Picos e região, quanto à importância e conservação das abelhas nativas do semiárido piauiense. O presente artigo tem como objetivo relatar as ações e impactos do referido projeto desenvolvido na Universidade Federal do Piauí, em Picos. Para isso, descreveu-se o projeto a partir da consolidação do espaço de aprendizagem, desde a formação dos acadêmicos e monitores até a realização das visitas. Os visitantes primeiramente assistem à uma aula, ministrada pelos próprios acadêmicos, sobre as abelhas e seguem para o Meliponário onde observam as abelhas em atividade. Durante as visitas a observação de algumas expressões espontaneamente pronunciadas pelos alunos, nos auxiliam a avaliar os impactos positivos do projeto para a conservação das abelhas nativas, como: “Professora, as abelhas são os cupidos da natureza!” De abril de 2018 a novembro de 2019 foram recebidos 560 visitantes da rede pública de ensino de Picos, de IES e de outros municípios. Considera-se que as ações educativas promovidas no Meliponário Didático da UFPI configuram estratégias eficazes e necessárias para a constituição de uma relação sustentável com as abelhas.
Palavras-chave: Caatinga; Educação Ambiental; Meliponicultura; Biodiversidade
Didactic meliponary: University extension as a strategy for the conservation of stingless bees in the Piauí semiarid
Abstract: Considering Environmental Education as an instrument of transformation and a priority among actions towards sustainable development, the university extension project "Didactic meliponary: a strategy for conservation of stingless bees in the semi-arid region of Piauí" aims to raise the awareness of children and young people, students of primary education in the municipality of Picos and region, regarding the importance and conservation of native bees in the semi-arid region of Piauí. This paper aimed to report the actions and impacts of the referred project developed at the Federal University of Piauí, in Picos, Piauí State, Brazil. The consolidation of the learning space and the training of the monitors to conduct the visits were described. Visitors first attend a class taught by the academics about bees and proceed to the meliponary ("Meliponário") to observe the active bees and their social structure. During the visits, expressions spontaneously pronounced by the students are noted, which helps us to assess the positive impacts of the project for the conservation of native bees. One of the expressions was: "Teacher, bees are nature's cupids!" From April 2018 to November 2019, 560 visitors from public schools in Picos, IES, and other municipalities were received. It is considered that the educational actions promoted at UFPI's Didactic Meliponary are an effective and necessary strategy for the constitution of a sustainable relationship with bees.
Keywords: Caatinga; Environmental Education; Meliponiculture; Biodiversity
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Matsuoka, Akira. "What made base erosion and profit shifting project possible?" Journal of Financial Crime 25, no. 3 (July 2, 2018): 795–810. http://dx.doi.org/10.1108/jfc-08-2017-0072.
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Purpose The purpose of this paper is to unveil the true background of the Base Erosion and Profit Shifting (BEPS) Project and to suggest crucial indexes for bringing a movement into a future ceiling causing a struggle of the international tax system. Design/methodology/approach This paper looks into the historical context of this project before and after Starbucks’ scandal, comparing to other contexts of the international tax system. Also, this paper partially reviews BEPS from a legal perspective. Findings The key factors for building momentum of reform of international taxation are a country having a government willing to embrace the cause of reform, unfairness felt toward entities using tax avoidance schemes which other comparable entities could not be use, grass-roots pressure for the reform, effective places to negotiate cooperation among major countries for the reform, solid cooperation among many countries in the world to implement standards and rhetoric of slogan with less opposition. Originality/value The momentum of the reform of international taxation was analyzed before. But the BEPS Project has involved some unique events as compared with the Organization for Economic Cooperation and Development’s project on harmful tax practices, such as initiation of NGOs and boycott by consumers. Additionally, this paper will discuss insights, which the former research did not do.
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Garbarino, Carlo. "The Impact of the OECD BEPs Project on Tax Treaties: Access, Entitlement and Investment Protection." European Business Law Review 31, Issue 5 (September 1, 2020): 763–98. http://dx.doi.org/10.54648/eulr2020029.
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In recent years aggressive tax strategies lead to a new phenomenon denominated by the OECD as ‘base erosion and profit shifting’ (Beps). The OECD and G20 countries adopted in 2013-15 a 15-point Action Plan to address Beps (the ‘Beps Project’). In respect to tax treaties the OECD adopted in 2016 a Multilateral Instrument and in 2017 issued a new release the Commentary to the OECD Model Tax Convention on Income and on Capital. These changes were approved as part of the Beps Project in Actions 2, 6, 7 and 14. The article describes the Model/Commentary 2017 and looks at the impact of the OECD Beps Pproject on tax treaties in terms of PE access, entitlement and investment protection The article focuses on three main dimensions for a resident of a Contracting State of doing business in the other Contracting State: first, the tests required for doing business through PE (section 2); second, the new set of requirements that need to be met to have full entitlement to the tax treaty (section 3); third, the basic rules for doing business through a corporate vehicle, once the entitlement requirements have been met (section 4). The article concludes with the discussion of tax treaty dispute settlement and enforcement by looking at the mutual agreement procedure, transfer price allocations in tax treaties, and tax treaties and information (section 5). Base erosion, profit shifting, tax avoidance, multilateral tax treaties, OECD Model Tax Convention, BEP s
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Gupta, Saloni, and Prabhat Mittal. "Base Erosion and Profit Shifting: The New Framework of International Taxation." Journal of Business Management and Information Systems 2, no. 2 (December 31, 2015): 108–14. http://dx.doi.org/10.48001/jbmis.2015.0202009.
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Base Erosion and Profit Shifting (BEPS) refers to a set of tax avoidance practices that deny the tax revenues to a nation by eroding the tax base of the nation where economic activities generating the profits are performed and where value is created, by shifting the tax incidence to locations where no or low taxes are payable (tax havens). BEPS can be achieved through the use of transfer pricing tactics, treaty shopping, digital economy maneuverings and other dubious means. The term BEPS has been used in a project headed by the OECD which produced final reports in October 2015 in response to fifteen action points agreed previously (July 2013). The BEPS project is an attempt by the world’s major economies to rewrite the rules on corporate international taxation so as to address the widespread perception that the corporations, especially MNCs, don’t pay their fair share of taxes. It seeks to ensure that MNCs report profits where economic activities are carried out and value is created.
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Akande, O. K., R. E. Olagunju, S. C. Aremu, and E. A. Ogundepo. "Exploring Factors Influencing of Project Management Success in Public Building Projects in Nigeria." YBL Journal of Built Environment 6, no. 1 (May 30, 2018): 47–62. http://dx.doi.org/10.2478/jbe-2018-0004.
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AbstractIn Nigerian, public building projects (PBPs) failure and abandonment constitutes one of the hindrances to the development of the nation’s economic system. Therefore, the links between PBPs management success and the built environment professionals (BEPs) is becoming an important field of attention. This study evaluates the application of project planning techniques in PBPs in Nigeria and project planning challenges related to their successful delivery. Review of relevant literature combined with experts’ input revealed twenty three factors; this form the basis for designing a questionnaire adopted to collect relevant data from BEPs. Findings identified poor strategic project planning aligned to project success, unrealistic expectation and overly bureaucratic hiccups from project initiators as the most critical factors influencing project management practices (PMP) affecting success in PBP delivery. The study suggests that unsuccessful project delivery is a reflection of inappropriately applied project planning techniques leading to serious project planning challenges.
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ITOH, Takahiro, Shinji EGASHIRA, Kuniaki MIYAMOTO, and Hirotaka TAKEUCHI. "TRANSITION OF DEBRIS FLOWS OVER RIGID BEDS TO OVER ERODIBLE BEDS." PROCEEDINGS OF HYDRAULIC ENGINEERING 43 (1999): 635–40. http://dx.doi.org/10.2208/prohe.43.635.
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Jiménez, Adolfo Martín. "BEPS, the Digital(ized) Economy and the Taxation of Services and Royalties." Intertax 46, Issue 8/9 (August 1, 2018): 620–38. http://dx.doi.org/10.54648/taxi2018067.
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The BEPS project has left untouched very relevant opportunities for base erosion and profit shifting, mainly with payments for services and royalties, by MNE groups or even smaller enterprises. It is surprising that the debate about the digital or digitalized economy focuses so much on solutions (the concept of PE based on significant digital economic presence, withholding taxes for digital provision of services or goods or equalization levies) that do not contribute significantly to end up the base erosion and profit shifting opportunities that the BEPS project did not consider, is concentrating on solutions that will not be very helpful in fully aligning tax bases and economic activity and even abandons the BEPS already agreed standards to create a high degree of uncertainty and fragmentation. The article explains why the solutions proposed in the current debate on Action 1 BEPS are insufficient or disproportionate (they may be more political patches than effective remedies), and why more attention should be paid to a more evolutionary approach of the already BEPS agreed principles and standards or the traditional thresholds for taxing business profits, including the UN MC as it is evolving. A more robust international tax order will require to ponder more carefully if already known and agreed principles (including some BEPS outcomes within them), as they can evolve, will be better options to permit ‘market states’ to tax economic activity and will create less uncertainty than the revolutionary solutions proposed in the debates on Action 1 BEPS or unilaterally by the EU or some States.
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Machehin, Viktor A. "International Taxation at the Beginning of the XXI Century: A New Reality." Zakon 20, no. 11 (November 2023): 20–31. http://dx.doi.org/10.37239/0869-4400-2023-20-11-20-31.
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The article analyses the main changes in international taxation at the beginning of the XXI century. The author highlights the changes in the system of tax international information exchange for individuals and the BEPS project for multinational companies. These changes were caused by the consequences of the 2008 crisis. A system of tax information exchange in digital form based on international tax agreements was built for individuals. To combat corporate international tax evasion, the G-20 and OECD presented a BEPS Action Plan consisting of 15 actions. This Plan is designed to prevent the chaos in international taxation as a result of uncoordinated tax actions of individual states. The main elements of the BEPS Action Plan are traditional anti-avoidance measures without fundamentally changing international tax rules based on taxation of individual companies belonging to multinational corporations. The BEPS Plan contains a new form of reporting, which is based on the assessment of a multinational company as a whole. In the future, the tax attitude towards a multinational company as a single business was developed in the BEPS 2.0 project. The author believes that it is necessary to develop the rules of taxation of multinational companies as a single unit to solve current problems with taxation of such companies.
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Merkx, Madeleine. "Fixed Establishments in European Value Added Tax: Base Erosion and Profit Shiftings Side Effects?" EC Tax Review 26, Issue 1 (February 1, 2017): 36–44. http://dx.doi.org/10.54648/ecta2017004.
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The focus in the Organisation for Economic Co-operation and Development (OECD) reports in the Base Erosion and Profit Shifting (BEPS) project is on direct taxation. Still, the effects BEPS will have on indirect taxes should not be underestimated. In this article the author addresses the effects the BEPS reports and developments will have on the concept of fixed establishment (FE) for indirect taxes. She addresses the changes in the concept of permanent establishment (PE) and how these may affect the interpretation of the concept of FE for Value Added Tax (VAT) purposes. On top of that, she discusses whether or not the issues addressed in BEPS for PEs need to be examined in a similar manner for FEs in European VAT.
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Valente, Piergiorgio. "Italian Perspective on BEPS and Focus on Implementation of Action 13 of the BEPS Action Plan." Intertax 44, Issue 8/9 (August 1, 2016): 666–72. http://dx.doi.org/10.54648/taxi2016055.
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Italy has been paying special attention, to recent developments in the struggle against tax evasion and avoidance. Many of the provisions recommended by the Organization for Economic Co-operation and Development within the context of the Base Erosion and Profit Shifting Project were introduced into, and enacted by, the National tax system, in particular, by effect of Legislative Decree No. 147 of 14 September 2015, which contained ‘Provisions setting forth measures for the development and the internationalization of enterprises’, and of Law No. 208 of 28 December 208 setting for ‘Provisions for the drawing up of the yearly and multi-year State Budget’.
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Grundmann, Stephanie, and Nina Langen. "GO-Sustainable – Mobile Hochbeete mit integrierter Wurmkiste: Ein fächerübergreifendes Projekt zur Nachhaltigen Ernährung." Haushalt in Bildung & Forschung 9, no. 2-2020 (June 19, 2020): 73–81. http://dx.doi.org/10.3224/hibifo.v9i2.06.
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Die Umsetzung der Vorschläge der EAT-Lancet Commission für die globale nachhaltige (Welt-)Ernährung kann nur Erfolg haben, wenn eine Veränderung im Essalltag aller Menschen sowie eine Steigerung der Wertschätzung von Lebensmitteln gelingt. Der Beitrag diskutiert am Beispiel des Projektes „GO-Sustainable Berlin“ die Chancen für Ganztagsschulen als Lern- und Lebensort durch fächerübergreifende Projekte.
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Lobo, Kenneth, and Robert G. Rinninsland. "US-Based Pushback on BEPS." Intertax 43, Issue 1 (January 1, 2015): 96–105. http://dx.doi.org/10.54648/taxi2015009.
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The US's Government's main goal is to prevent other countries from taxing what it views as "its" tax base through Base erosion and profit shifting (BEPS). While the US broadly agrees that the issues addressed by BEPS should be remedied, they disagree that a multilateral framework is the best solution for some of these problems. In this regard, US lawmakers and regulators have publicly expressed doubt about the progress and effectiveness of the BEPS project. Along with the US corporate community, concerns are that: (i) there are areas of international tax law that are the province of the US and should be managed as such without the layering on top of a newly created set of rules and principles, (ii) the basic tenet of transfer pricing, the arms-length standard, should remain a cornerstone of international tax; and, (iii) US international tax reform is urgently needed to either compliment BEPS Action Plans, to protect US economic interests that would be adversely affected by implementation of BEPS or a combination of both.
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Öner, Cihat. "Country Note: Analysis of Turkey’s Controlled Foreign Company Regime." Intertax 50, Issue 5 (April 1, 2022): 466–75. http://dx.doi.org/10.54648/taxi2022041.
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This study analyses Turkey’s current position against the policies it has carried out, especially regarding the controlled foreign companies (CFC) taxation regime by the Organization for Economic Cooperation and Development (OECD). As a member of the OECD and G20 during both the preparation and processing of the OECD’s Base Erosion and Profit Shifting (BEPS) Project, Turkey has undertaken various roles. Nevertheless, it is observed that existing CFC rules and current developments regarding Turkey’s CFC regime fall below the minimum standards recommended in the BEPS Action 3 Final Report, and there is a certain ‘resistance’ that continues to regulate some matters. This study seeks to critically analyse and display Turkey’s position for coping with the BEPS Action Plan concerning CFC regulations. Controlled Foreign Company (CFC), Base Erosion and Profit Shifting (BEPS), Turkish Corporate Income Taxation, International Taxation Principles, Tax Avoidance.
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Flaminio, Simone, Rosa Ranalli, Laura Zavatta, Marta Galloni, and Laura Bortolotti. "Beewatching: A Project for Monitoring Bees through Photos." Insects 12, no. 9 (September 18, 2021): 841. http://dx.doi.org/10.3390/insects12090841.
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Bees play a key role in natural and agro-ecosystems and their diversity is worldwide threatened by anthropogenic causes. Despite this, there is little awareness of the existence of the numerous species of wild bees, and the common name “bee” is very often exclusively associated with Apis mellifera. Our aim was to create a citizen science project in Italy with the following objectives: (a) raising awareness of the importance and diversity of bees, (b) obtaining data on the biology, ecology and distribution of Italian species, and (c) launching the monitoring of alien bees. The first step of the project was to create a website platform with a section containing informative datasheets of the wild bee families and of the most common bee genera present in Italy, a form to send reports of observed bees and an interactive map with all citizen’s reports. During the 2 years of the project 1086 reports were sent by 269 users, with 38 Apoidea genera reported on 190 plant genera; furthermore, 22 reports regarding the alien species Megachile sculpturalis arrived. The majority of bees (34 genera) were observed on spontaneous plants, including 115 genera native to Italy. Considering the increasing number of reports and data obtained in these first two years of the project, our objectives seem to be achieved. Future steps will be to outline the profile of beewatchers, to plan activities in a more targeted way, and also to start some sub-projects for conservation purposes.
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Valente, Piergiorgio. "BEPS Action 15: Release of Multilateral Instrument." Intertax 45, Issue 3 (March 1, 2017): 219–28. http://dx.doi.org/10.54648/taxi2017018.
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The release of the Multilateral Instrument constitutes an important step towards the most significant re-write of international tax rules in a `century. It is the multilateral convention enabling the simultaneous amendment of more than 3,000 existing bilateral conventions for the avoidance of double taxation. It aims at eliminating loopholes and mismatches among them, which are susceptible to allow aggressive tax planning. In thirty-nine articles, it implements measures indicated in Actions 2, 6, 7 and 14 of the Base Erosion and Profit Shifting (BEPS) Project, regarding hybrid mismatches, treaty abuse, artificial avoidance of permanent establishment status and dispute resolution of international tax disputes.
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Moreno, Andrés Báez. "GAARs and Treaties: From the Guiding Principle to the Principal Purpose Test. What Have We Gained from BEPS Action 6?" Intertax 45, Issue 6/7 (June 1, 2017): 432–46. http://dx.doi.org/10.54648/taxi2017036.
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The issue of General Anti-Avoidance Rules (GAARs) and treaties is a legal problem as old as double tax conventions themselves. However, the Base Erosion and Profit Shifting (BEPS) Project, materialized in fifteen Actions and particularly in the Final Report of BEPS Action 6, involves a radical change in the very physiognomy of the problem. Apart from the inclusion of a Limitation-on-benefits rule in the OECD Model, the most groundbreaking innovation arising from BEPS Action 6 would be the incorporation, also to the Model, of a GAAR (the Principal Purpose Test). This article will examine the pros and cons of the Principal Purpose Testvis á vis the old paradigm. It also seeks to analyse some new problems originating from the very existence of the PPT.
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Burkhalter-Martinez, Natassia. "BEPS Action 4 and Its Compatibility with the Principle of Non-Discrimination Under Article 24(4) of the OECD Model Convention." Intertax 47, Issue 1 (January 1, 2019): 55–65. http://dx.doi.org/10.54648/taxi2019004.
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The final reports of the OECD Base Erosion and Profit Splitting (BEPS) Project were published in October 2015. The OECD’s recommendations include an approach to address the risks of base erosion and profit shifting caused by the deduction of interest and other financial payments, namely by implementing a fixed ratio rule, which can be complemented by a group ratio rule. The implementation of the BEPS Action 4 recommended approach could lead to certain issues related to its compatibility with domestic law and with tax treaty obligations. This article addresses one of these issues by analysing the compliance of the BEPS Action 4 recommended approach with tax treaty obligations, mainly with the principle of nondiscrimination under Article 24(4) of the OECD Model Convention.
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Mosquera Valderrama, Irma Johanna. "Regulatory Framework for Tax Incentives in Developing Countries After BEPS Action 5." Intertax 48, Issue 4 (April 1, 2020): 446–59. http://dx.doi.org/10.54648/taxi2020039.
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The aim of this article is to assess the regulatory framework of Base Erosion Profit Shifting Project (BEPS) Action 5 in order to evaluate tax incentives in the form of preferential tax regimes that provide benefits to geographically mobile business income in developing countries. To conduct this assessment, this article first addresses the use of preferential tax regimes considering BEPS Action 5. Thereafter, and taking into account the concerns expressed by international organizations, regional tax organizations and scholars, the author contends that the evaluation of tax incentives in light of BEPS Action 5 results in additional burden for developing countries. Countries will need to assess their tax incentives considering the factors provided by the 1998 OECD report and BEPS Action 5. Since there are no terms of reference for the application of these factors, the country will have to assess its own tax incentives, which brings increased uncertainty and compliance burden for developing countries. In order to provide some guidance in this evaluation, the author provides a list of the factors used by the 1998 OECD report and BEPS Action 5 and their application to tax incentives. Subsequently, this article will assess the legitimacy of the application of BEPS Action 5 to developing countries and will demonstrate that its assessment framework is ambiguous and prevents developing countries from enacting legitimate tax incentives. Finally, this article will conclude and provide some recommendations for further research. BEPS, tax incentives, harmful tax, fair tax competition, developing countries
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Monsenego, Jérôme. "A Conference on the Impact of the BEPS Project on Business Models." Intertax 44, Issue 10 (October 1, 2016): 726–29. http://dx.doi.org/10.54648/taxi2016060.
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Mosquera Valderrama, Irma Johanna. "BEPS principal purpose test and customary international law." Leiden Journal of International Law 33, no. 3 (May 27, 2020): 745–66. http://dx.doi.org/10.1017/s0922156520000278.
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AbstractThe overall aim of this article is to analyse the principal purpose test as an emerging rule of customary international tax law. By means of the principal purpose test, the tax administration can deny the tax treaty benefit if one of the principal purposes of the action undertaken by the taxpayer was to obtain a benefit. This principal purpose test has been developed by the OECD with the political support of the G20 as one of the actions to tackle Base Erosion and Profit Shifting by multinationals (BEPS Project). At the time of writing, 137 jurisdictions including non-OECD, non-G-20 countries have committed to the implementation of the principal purpose test in their current and future tax treaties. Based on the analysis of the objective element (state practice) and subjective element (accepted as law), there are indications that this principal purpose test can emerge as a principle of customary international law. In the past, international tax law scholars addressed the customary international law regarding the OECD/UN tax treaty Models, the OECD Harmful Tax Practices, and the arm’s length principle. However, current international tax developments, including the BEPS Project, call for an analysis of the main elements of customary international law in respect of the principal purpose test, a general anti-avoidance rule that by its own nature, is often general, vague, and imprecise. Therefore, the findings of this article can be useful for generating new areas of research by international public law, international law, and international tax law experts.
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Eisenbeiss, Justus. "BEPS Action 7: Evaluation of the Agency Permanent Establishment." Intertax 44, Issue 6/7 (June 1, 2016): 481–502. http://dx.doi.org/10.54648/taxi2016039.
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The article is devoted to one of the most controversial items of the Base Erosion and Profit Shifting (BEPS)-Project – Action 7, particularly the agency Permanent Establishment (PE) of Articles 5(5) and 5(6). Marking the threshold for source-state taxing rights, the PE has been at the centre of an entrenched debate since the concept’s emergence in the nineteenth century. Thus, working on the agency PE the OECD soon found itself caught between a rock and a hard place. With strong national interest for a high threshold on the one side and the increasing need to rebalance taxing rights due to globalization and the emergence of modern business models on the other side. This conflict shaped the consolations process and final output of Action 7. Ultimately, the Final Report settled for much less than the initially pursued globally supported holistic approach. The need for a substantial reform, however, remains and becomes more pressing with the introduction of unilateral measures. Moreover, with the agency PE in the spotlight, attention will inevitably be directed to the attribution of profits, an issue neglected in the BEPS Project. The inadequacies of the current attribution rules are examined in the second part of this article and a proposal is put forward.
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Mosquera Valderrama, Irma Johanna. "The OECD-BEPS Measures to Deal with Aggressive Tax Planning in South America and Sub-Saharan Africa: The Challenges Ahead." Intertax 43, Issue 10 (October 1, 2015): 615–27. http://dx.doi.org/10.54648/taxi2015060.
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The aim of this article is to assess the feasibility to introduce the Organisation for Economic Co-operation and Development (OECD)-BEPS measures to deal with aggressive tax planning in South America and Sub-Saharan Africa. The BEPS and its Action Plan have been developed by the OECD following the G20 mandate and it provides new international tax standards to be applicable to all countries including OECD and non- OECD countries. This article will provide a comparative analysis of the South America and the Sub-Saharan African region taking into account the country’s economic development, tax administration capacity and resources, and the use (or not) of domestic laws and tax treaty rules to tackle aggressive tax planning. The South American and Sub-Saharan African regions have been chosen since they consist mostly of developing (non- OECD) countries. The comparative analysis of the exchange of best practices and challenges in these two regions will be useful for the OECD-BEPS Project and for the BEPS Multilateral Instrument that will be open for adoption by developing and developed countries. This article is structured as follows: Section 2 contains a short introduction to the BEPS Actions dealing with aggressive tax planning and the discussions at OECD and UN level. Section 3 will provide the assessment of feasibility of the BEPS in South America and Sub-Saharan Africa. Finally, in section 4, conclusions and recommendations will be presented.
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Silveira Borges, Gustavo, and Maurício Da Cunha Savino Filó. "Os bens comuns e a recepção pelo Direito Civil: análise a partir da experiência italiana." Revista Justiça do Direito 34, no. 1 (April 30, 2020): 220–49. http://dx.doi.org/10.5335/rjd.v34i1.10386.
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O presente artigo tem por objetivo refletir sobre a validade jurídica dos bens comuns, a partir do projeto de lei de iniciativa popular italiano (Progetto di legge di iniziativa popolare). Utiliza-se o método dedutivo de abordagem e o método de procedimento monográfico. O texto desenvolve-se em duas seções: “DireitoRomano e a codificação dos bens comuns” e “Contributos do direito civil italiano para os bens comuns: análise do projeto da Comissão Rodotà”. Conclui-se pela necessidade de se (re)pensar a as categorias de bens existentes nos Ordenamento Jurídicos, sobretudo a possibilidade da abertura do sistema jurídico para os bens comuns.
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AKANDE, Oluwafemi Kehinde, Lilian Chioma OBI-GEORGE, Jonam Jacob LEMBI, Ibrahim Adamu UMAR, Amos Musa TARNI, Adanna Joy NWOKORIE, and Paul Haruna BABA. "Public Housing Project Delivery in Nigeria: Quality versus Quantity." Journal of Contemporary Urban Affairs 8, no. 1 (January 21, 2024): 37–56. http://dx.doi.org/10.25034/ijcua.2024.v8n1-3.
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The outbreak of COVID-19 and its consequences have altered people's perceptions of the availability of high-quality housing. Nigeria, the most populous country in sub-Saharan Africa, has taken many initiatives to address its growing population's housing demands. However, considerable focus has been placed only on housing quantity at the expense of housing quality. This study aims to investigate the interplay of factors affecting the provision of high-quality public housing projects in Nigeria. The objective is to identify the factors that significantly influence project success and failure in the delivery of quality public housing projects. A descriptive survey design with 351 randomly selected households and built environment experts (BEPs) was used. A self-developed structured questionnaire was used to collect data from households, buildings, and professionals over the course of three months. The findings indicate that in several buildings, the indoor air temperature and relative humidity extend acceptable limits (for example, 28 °C and 70% RH), which can have an effect on indoor air quality. Meanwhile, responses from the BEPs revealed that in order to develop high-quality housing, adequate project financing, evaluation of suitable building materials, and project management expertise were required. The study's conclusion emphasises that considering only the number of houses required to accommodate Nigeria's growing urban population is insufficient; rather, other factors such as appropriate design for improved air quality, high-quality and appropriate building materials, adequate project financing, and project management expertise would result in the quality delivery of livable public housing in Nigeria.
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Hignett, Sue, and Richard Lang. "Project-managing a change to electric hospital beds." British Journal of Healthcare Management 9, no. 8 (August 2003): 271–76. http://dx.doi.org/10.12968/bjhc.2003.9.8.18852.
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Tell, Michael. "Interest Limitation Rules in the Post-BEPS Era." Intertax 45, Issue 11 (November 1, 2017): 750–63. http://dx.doi.org/10.54648/taxi2017065.
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The use of debt is, according to the OECD, one of the simplest profit-shifting techniques available in international tax planning, due to the mobility of money. A debt tax planning strategy can be applied without any people or machinery being moved or re-allocated; it can be done by advisors or in-house specialist sitting at their desks. These (lawful) tax planning strategies undermine the fairness and integrity of tax systems, because multinational entities can use Base Erosion and Profit Shifting (BEPS) strategies to gain a competitive advantage over domestic entities, as well as undermining voluntary compliance by all taxpayers, according to the OECD. The focus in the OECD BEPS project and the Anti-Tax Avoidance Directive (ATAD) is to counteract these tax planning strategies to ensure taxation where the value is created (economic activity). This article focuses on one anti-tax avoidance measure: interest limitation rules as addressed in BEPS action 4 and in ATAD Article 4. The aim of the article is to address the need for interest limitation rules, analyse the recommend approached in BEPS action 4, analyse the minimum interest limitation rule in the EU according to Article 4 in ATAD, and the implications of OECD action 4 and ATAD Article 4. Lastly, the article will discuss alternatives to these interest limitation rules as a way to address BEPS.
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Brauner, Yariv. "Transfer Pricing in BEPS: First Round Business Interests Win (But, Not in Knock-Out)." Intertax 43, Issue 1 (January 1, 2015): 72–84. http://dx.doi.org/10.54648/taxi2015006.
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Reforming the transfer pricing regime is not merely one of many equal tasks faced by the BEPS initiative; it is its core task. The Organisation for Economic Co-operation and Development (OECD) has responded to the challenge with an ambitious plan to reform the substantive transfer pricing rules so that they could realistically meet the challenges of sophisticated tax planning - particularly of transactions involving intangibles - and to standardize reporting to reduce compliance and enforcement costs for all stakeholders. On September 2014 the OECD has delivered only partially on these promises, progressing very little on the substantive reform front, yet meeting the not less important goal of standardizing transfer pricing reporting. The article takes a critical look at the progress of the BEPS project in the transfer pricing area, and makes recommendations to support the OECD's original intentions as articulated in the initial Base Erosion and Profit Shifting (BEPS) reports.
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Eduardo Schoueri, Luís, and Ramon Tomazela. "The Influence of the BEPS Multilateral Instrument on Tax Treaties Concluded by Non-signatory Countries." Intertax 49, Issue 10 (October 1, 2021): 818–43. http://dx.doi.org/10.54648/taxi2021080.
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This article intends to assess the impact of the Base Erosion and Profit Shifting Project (BEPS) Multilateral Instrument (MLI) on tax treaties concluded by non-signatory jurisdictions. To achieve this goal, the authors initiated the analysis with forty-four countries that are members the BEPS Inclusive Framework but have not yet signed the MLI. Out of these forty-four countries, the authors focused on those that had tax treaties signed or amended after 2017 which has narrowed down the scope to the following countries: Angola, Botswana, Brazil, Cape Verde, Congo, Maldives, Thailand, and Vietnam. In this context, the article examines the tax treaty-related BEPS measures that were adopted by these countries in their bilateral tax treaties, addressing the merits and potential consequences of the choices made by non-signatory jurisdictions. Based on the findings of the research, the article concludes that the impact of the MLI varies significantly depending on the tax treaty policy of each country and that, thus far, it has been limited primarily to the minimum standards on dispute resolution. Multilateral instrument, non-signatory countries, tax treaty policy, minimum standard, bilateral tax treaty negotiation, BEPS implementation, hybrid mismatches, treaty abuse, permanent establishment, dispute resolution.
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AKEDA, Sadamitsu, Kenji YANO, and Yoshiaki TAKAHASHI. "Artificial formation of seaweed beds on concrete structure." PROCEEDINGS OF CIVIL ENGINEERING IN THE OCEAN 11 (1995): 145–50. http://dx.doi.org/10.2208/prooe.11.145.
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MICHIUE, Masanori, Masaharu FUJITA, and Shigeyuki KUSAKABE. "Formation of Meandering Streams in Mountain River Beds." PROCEEDINGS OF HYDRAULIC ENGINEERING 39 (1995): 613–18. http://dx.doi.org/10.2208/prohe.39.613.
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OKABE, Takeshi, Toyokatsu YUUKI, and Maki KOJIMA. "Bed-Load Rate on Movable Beds with Vegetation." PROCEEDINGS OF HYDRAULIC ENGINEERING 41 (1997): 851–56. http://dx.doi.org/10.2208/prohe.41.851.
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Fehling, Daniel. "Critical Review Of The Atad Implementation: Addressing Base Erosion and Profit Shifting: The Implementation of the ATAD in Germany." Intertax 50, Issue 10 (August 1, 2022): 721–29. http://dx.doi.org/10.54648/taxi2022076.
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Germany has been an active supporter of the Base Erosion and Profit Shifting (BEPS) Project from its initiation and has also whole-heartedly supported the implementation of core BEPS recommendations in Europe through the anti-tax avoidance directive (ATAD). However, the subsequent domestic implementation process took longer than expected. It was only in June 2021 that the last remaining pieces of the ATAD were transposed into German tax law. This article explains Germany’s perspective on the ATAD more generally and describes which parts of domestic tax law have been amended in order to ensure conformity with the directive. ATAD implementation in Germany, CFC, interest deduction limitation, GAAR, exit taxation, hybrid mismatches
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Baker, Philip, and Philip Baker. "BEPS Action 16: The Taxpayers Right to an Effective Legal Remedy Under European Law in Cross-Border Situations." EC Tax Review 25, Issue 5/6 (November 1, 2016): 335–45. http://dx.doi.org/10.54648/ecta2016033.
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This article starts from the reasonable assumption that the implementation of the base erosion and profit shifting (BEPS) project increases legal uncertainty in tax matters. The shift from the isolated and bilateral exercise of taxing jurisdiction to international tax coordination in the framework of the BEPS project is not accompanied by a corresponding global convergence in the exercise of legal remedies, which remain confined to their national boundaries. In line with their previous research, the authors address hereby the right of taxpayers to an effective legal remedy under European tax law, taking into account the dialogue among Courts in respect of legal values contained in national Constitutions of European Union (EU) Member States, the EU Charter of Fundamental Rights and the European Convention on Human Rights. The focus is on the right to an effective legal remedy in cross-border tax procedures, with special emphasis on mutual agreement procedures and mutual assistance. The authors suggest a two-tier mechanism with the involvement of taxpayers and tax authorities, which allows for an effective exercise of the right of defence and does not require major changes in the wording of treaty clauses modelled after Articles 25 and 26 OECD MC. Hopefully, something that other international institutions, including the United Nations, may consider for the future. The authors suggest filling this gap with their proposal for a BEPS Action 16.
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Herrington, M., and C. Lowell. "The BEPS Project: Planning in Anticipation." International Transfer Pricing Journal 21, no. 3 (May 12, 2014). http://dx.doi.org/10.59403/25s4bmc.
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The authors focus in more detail on some of the specific transfer pricing-related changes that could flow from the BEPS project and offer their insights into how multinationals can be positioning themselves in anticipation.
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Gajewski, Dominik J. "Regulacje z zakresu międzynarodowego prawa podatkowego a wdrożenie działań BEPS." Studia BAS 2, no. 54 (2018). http://dx.doi.org/10.31268/studiabas.2018.06.
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Brauner, Yariv. "What the BEPS?" Florida Tax Review 16, no. 2 (December 9, 2019). http://dx.doi.org/10.5744/ftr.2014.1602.
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Unprecedented attention to aggressive international tax planning has shaken the earth under the most powerful players in the world of international tax policy design. The media exposure of what Bloomberg’s calls “The Great Corporate Tax Dodge,” combined with the ever-growing discontent of civil society with the magnitude of contribution of the largest multinational enterprises to the society within which they operate, has recently forced the politicians to take action. Leaders of the strongest world economies demanded a revision of the rules of the international tax regime that would generate more revenues for their challenged coffers and would restore public trust in the system. In what is now commonly known as the Base Erosion and Profit Sharing (“BEPS”) project, the OECD has established three principles: (1) promotion of collaborative rather than competition based solutions; (2) take a holistic view of the challenges and their corresponding solutions rather than an ad hoc approach; and (3) permit the consideration of innovative solutions even when they conflict with the traditional premises of the current international tax regime. This Article reviews the progress of the BEPS project and its compatibility with the fundamental principles for reform set by the OECD with a view to influence the discourse and the outcome of the project. This Article focuses on the importance of the paradigm shift from the current emphasis on competitiveness and the perfection of competition to a collaborative international tax regime, demonstrating the desirability of such a shift and suggesting how the OECD should go about making that shift.
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Herrington, M. "The OECD BEPS Project: A Status Update." International Transfer Pricing Journal 22, no. 4 (July 2, 2015). http://dx.doi.org/10.59403/1nz9awp.
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An overview of the BEPS-related papers, recently published by the OECD on 6 February 2015, is provided and this article furthermore attempts to explain the OECD’s proposed timeline for implementing the recommendations set out in those papers.
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Andrade Rodríguez, B. "Implementation v. Adaptation: BEPS in Latin America through the Lens of the ILADT Model." World Tax Journal 9, no. 3 (August 3, 2017). http://dx.doi.org/10.59403/2rh9mb1.
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There are specific reasons to affirm that the BEPS Project is not fully suited to addressing the needs of Latin American countries. Therefore, adaptations to several of the BEPS Actions included in the Project are necessary. The drafting of the Multilateral Instrument as proposed in BEPS Action 15 could constitute a proper scenario for submitting and addressing the specific concerns and proposals of the region with respect to the BEPS Project. The author proposes the use of the ILADT Model to address, systematize and generate a sole proposal for the region in order to represent the needs of the region in the drafting of the Multilateral Instrument.