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COMBATTRE LES PARADIS FISCAUX |
CE QUI A ÉTÉ FAIT -
CE QUI DEVRAIT ÊTRE FAIT
ANNEXES
One focus will be international tax schemes, where
the work will explore using a wide definition of “tax
benefit” in order to capture such transactions. The
work will be co-ordinated with the work on co-op-
erative compliance. It will also involve designing
and putting in place enhanced models of informa-
tion sharing for international tax schemes between
tax administrations.
ACTION 13
RE-EXAMINE TRANSFER PRICING
DOCUMENTATION.
Develop rules regarding transfer pricing documen-
tation to enhance transparency for tax adminis-
tration, taking into consideration the compliance
costs for business. The rules to be developed
will include a requirement that MNE’s provide all
relevant governments with needed information on
their global allocation of the income, economic ac-
tivity and taxes paid among countries according to
a common template on a country by country basis.
ACTION 14
MAKE DISPUTE RESOLUTION
MECHANISMS MORE EFFECTIVE.
Develop solutions to address obstacles that pre-
vent countries from solving treaty-related disputes
under MAP, including the absence of arbitration
provisions in most treaties and the fact that access
to MAP and arbitration may be denied in certain
cases.
ACTION 15
DEVELOP A MULTILATERAL
INSTRUMENT.
Analyse the tax and public international law issues
related to the development of a multilateral instru-
ment to enable jurisdictions that wish to do so to
implement measures developed in the course of
the work on BEPS and amend bilateral tax treaties.
On the basis of this analysis, interested Parties will
develop a multilateral instrument designed to pro-
vide an innovative approach to international tax
matters, reflecting the rapidly evolving nature of
the global economy and the need to adapt quickly
to this evolution.