Mar 20, 2020 Poland's mandatory disclosure requirements (MDR) that implement the of action 12 of the OECD's base erosion and profit shifting (BEPS)

One BEPS recommendation that could spawn legal questions that have human rights implications is BEPS Action 12 – Mandatory Disclosure Rules (MDR). Unlike the rest of the recommendations, BEPS Action 12 is a pre-emptive or proactive measure3 that requires taxpayers to provide regulators with

This report is an output of Action 12. Beyond securing revenues by realigning taxation with economic activities and value creation, the OECD/G20 Action 12: Mandatory Disclosure Rules (the “Discussion Draft”). EBIT Members generally welcome the OECD’s efforts aimed at providing further detailed guidance on how a standard framework for Mandatory Disclosure Rules (MDR) could help to combat BEPS, although we have a number of concerns with the Discussion Draft, which we outline below. OECD/G20 BEPS Action 12 Final Report from 2015. Compared to the OECD Mandatory Disclosure Rules for CRS Avoidance Arrangements and Opaque Offshore Structures (OECD MDR), the scope of arrangements covered by DAC6 is much broader • The goal of the implementation of DAC6 is to provide the tax authorities of EU member states with information DAC6 responds to the recommendations of Action 12 of the OECD/G20 Base Erosion and Profit Shifting (‘BEPS’) project regarding the Mandatory Disclosure Rules (‘MDR’).

Beps action 12 mdr

If you should have any questions on the comments below or on AOTCA or CFE, please contact Rudolf Reibel, CFE Fiscal and Professional Affairs Officer, at the CFE office: brusselsoffice@cfe-eutax.org. OECD. On 15 July 2019, the OECD announced that it is now gathering input on the implementation of the BEPS Action 14 minimum standard in relation to the review of the ninth batch of jurisdictions (Andorra, Anguilla, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Faroe Islands, Macau (China), Morocco and Tunisia) and invites taxpayers to submit their input related to their BEPS Action 12: $ " ! 4 September 2019. Page 1 EU Mandatory Disclosure Regime (DAC6) An Overview of the MDR Regime X.lØ.W to the BEPS Actions: Action 1 Digital economy Action 2 Hybrids Action 3 CFC rules Action 4 Interest deduction Action 5 Harmful Tax practices IP regime Action 6 Treaty Abuse Action 7 Permanent establishment Action 8-10 Transfer Pricing Action 11 BEPS Data Analysis Action 12 Mandatory Disclosure Rules Action 13 Transfer Pricing documentation DAC6/MDR: Regeringen har beslutat om att justera tidsfristerna för rapporteringen med sex månader DAC6: Justering av tidsfristerna för rapporteringen DAC6 träder i kraft den 1 juli 2020 men regeringen har nu beslutat att man skjuter på själva tidsfristerna för rapporteringen i Sverige med sex månader.

23 jekt om Base Erosion och Profit Shifting (BEPS) har nya inter- nationella flesta OECD-länder (även Sverige) tillåter att FoU-kostnader kan skrivas av som 12 Ett vanligt argument är att den ökade vinst som företagen får genom den lägre Skatteincitamenten hade orsakat uteblivna skatteintäkter på 7 mdr dollar OECD, 2013a, Action Plan on Base Erosion and Profit Shifting.

9 Action 12 – Mandatory disclosure rules • Tax authorities face a lack of timely, comprehensive and relevant information on aggressive tax planning which can be addressed by mandatory disclosure rules (“MDR…

The lack of timely, comprehensive and relevant information on aggressive tax planning strategies is one of the main challenges faced by tax authorities worldwide. Mandatory disclosure regimes can enable countries to quickly respond to tax risks by providing early access to such information.

BEPS Action 12 aims to increase the information flow on tax risks to tax administrations and tax policy makers. Recommendations provide a modular framework that enables countries without mandatory disclosure rules to design a regime that fits their need to obtain early information on potentially aggressive or abusive tax planning schemes and their users.

Svenska Försäljning, rörelsemarginal 2011–2015. Resultat per aktie. 7,6 MDR 12 lindab | värdekedja.

In particular, we are uncertain at Action 12: Mandatory Disclosure Rules (the “Discussion Draft”). EBIT Members generally welcome the OECD’s efforts aimed at providing further detailed guidance on how a standard framework for Mandatory Disclosure Rules (MDR) could help to combat BEPS, although we have a number of concerns with the Discussion Draft, which we outline below. informed risk assessment, audits, or changes to legislation or regulations. Action 12 of the Action Plan on Base Erosion and Profit Shifting (BEPS Action Plan, OECD, 2013) recognised the benefits of tools designed to increase the information flow on tax risks to tax administrations and tax policy makers.
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Effective in achieving their objectives. Accurately identify the schemes to be disclosed. In view of this, the G-20 (group of 20, which brings together the world’s major advanced and emerging economies, comprising the EU and 19 country members) and the Organization for Economic Co-operation and Development (OECD) issued Base Erosion and Profit Shifting (BEPS) Action 12, which provides recommendations for the design of rules to detect aggressive tax planning arrangements and This comes as no surprise since the Action Plan on BEPS states that the definition of “tax benefit” under Action 12 should be wide to capture international tax schemes. Although that may very well be the case, the fact that the definition is so wide will also lead to that a huge number of transactions, being of little interest from a BEPS BEPS Action 12 aims to increase the information flow on tax risks to tax administrations and tax policy makers.

Business taxpayers are encouraged to take this opportunity to submit their views.
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•Second Set of Deliverables: Action 3 (CFC rules), Action 4 (Interest), Action 5 (HTP), Action 7 (PE Avoidance), Action 8-10 (TP), Action 11 (Economic Analyses), Action 12 (MDR), Action 14 (MAP) October 2015 •Completion and Final Deliverables: Completion of BEPS Project and delivery of all supplemental reports to the G20 Finance Ministers

It affects at least one EU Member State that falls within one of several categories or “hallmarks”. BEPS Action 12 - Disclosure of Aggressive Tax Planning BEPS Action 12 “Mandatory disclosure rules” aims to require taxpayers to disclose their aggressive tax planning arrangements. This will be addressed through the development of recommendations regarding the design of mandatory disclosure rules for aggressive or abusive transactions, arrangements, or structures, taking into consideration BEPS Action 12 aims to increase the information flow on tax risks to tax administrations and tax policy makers. Recommendations provide a modular framework that enables countries without mandatory disclosure rules to design a regime that fits their need to obtain early information on potentially aggressive or abusive tax planning schemes and their users. On 5 October 2015, the OECD released its final report on mandatory disclosure rules (Action 12) under its Action Plan on Base Erosion and Profit Shifting (BEPS). 1 The Action 12 Report made a series of recommendations regarding the design of mandatory disclosure regimes, intended to allow maximum consistency between countries while also being sensitive to local needs and to taxpayers In view of this, the G-20 (group of 20, which brings together the world’s major advanced and emerging economies, comprising the EU and 19 country members) and the Organization for Economic Co-operation and Development (OECD) issued Base Erosion and Profit Shifting (BEPS) Action 12, which provides recommendations for the design of rules to detect aggressive tax planning arrangements and In terms of relevant taxes, the MDR applies to all taxes of any kind levied by, or on behalf of, an EU Member State or the Member State’s territorial or administrative subdivisions, including the 4 See Final Report on BEPS Action 2, p.