THE OECD has invited comments on a Discussion Draft which
deals with Action 12 (Mandatory Disclosure Rules) of the BEPS Action Plan.
In July 2013, the Action Plan on Base Erosion and Profit Shifting directed
the OECD to commence work on 15 actions designed to ensure the coherence of
corporate income taxation at the international level. The first seven of these
actions were presented to G20 Leaders at the Brisbane Summit in November 2014.
This discussion draft provides an overview of mandatory disclosure regimes,
based on the experiences of countries that have such regimes, and sets out
recommendations for a modular design of a mandatory disclosure regime including
recommendations on rules designed to capture international tax schemes.
The Discussion Draft sets out a standard framework for a mandatory disclosure
regime that ensures consistency while providing sufficient flexibility to deal
with country specific risks and to allow tax administrations to control the
quantity and type of disclosure. The Discussion Draft is divided into four
chapters as follows:
Chapter I is the introduction of this document.
Chapter II provides an overview of the key features of a mandatory disclosure
regime and considers its interaction with other disclosure initiatives and
compliance tools.
Chapter III sets out both the framework and features for the modular design
of a mandatory disclosure regime.
Chapter IV looks at international transactions and considers how these could
best be captured by a mandatory disclosure regime.
The Action Plan calls for this work to be completed by September 2015. As part
of the transparent and inclusive consultation process mandated by the Action
Plan, the CFA invites interested parties to send comments on this discussion
draft.
Comments
should be submitted by April 30, 2015 at the latest (no extension will be
granted) by email to mandatorydisclosure@oecd.org in Word format.
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