TEI Files Comments on OECD Pillar One and Pillar Two Blueprints
On December 13, TEI submitted comments to the OECD regarding its BEPS Project Pillar One and Pillar Two Blueprints. TEI’s comments focused on the specific questions posed by the OECD in its consultation document, including issues related to Amounts A and B under Pillar One, as well as the GloBE under Pillar Two.
TEI Files Comments regarding 2020 OECD Review of CbC Reporting
On March 5, TEI submitted comments to the OECD regarding its public consultation document entitled Review of Country-by-Country Reporting (BEPS Action 13).
TEI Comments on the OECD’s “GloBE” Proposal
On December 2, TEI filed comments responding to the OECD’s public consultation document entitled Global Anti-Base Erosion Proposal (“GloBE”) – Pillar Two, focusing on the need for states to withdraw unilateral measures, a strong binding dispute resolution mechanism, and clear ordering rules, among other things.
TEI Files Comments regarding the OECD Secretariat’s “Unified Approach” to Pillar One
On November 11, TEI submitted comments to the OECD Secretariat regarding its proposed “unified approach” to “Pillar One” of the tax challenges of the digitalization of the economy. TEI’s comments focused on the need for (i) the withdrawal of unilateral measures after a multilateral agreement, (ii) a multilateral dispute resolution mechanism; and (iii) reliance on taxpayer consolidated financial statements for purposes of the approach, among other subjects.
TEI Submits Comments to the OECD regarding Digitalization of the Economy Consultation
On March 4th, TEI submitted comments to the OECD regarding its public consultation document entitled Addressing the Tax Challenges of the Digitalisation of the Economy. TEI will also participate in in the upcoming public consultation on March 13-14 in Paris.
TEI Submits Comments to the Treasury and IRS regarding Proposed Regulations under Section 965
On October 9th, TEI submitted comments to the Treasury and IRS regarding proposed regulations promulgated under the transition tax imposed by section 965, as amended by the Tax Cuts & Jobs Act enacted in 2017.
TEI Submits Comments to the OECD regarding the Transfer Pricing aspects of Financial Transactions
On September 6th, TEI submitted comments to the OECD regarding its public discussion draft under BEPS Actions 8-10 on the transfer pricing aspects of financial transactions.
TEI Comments on Scope of Revisions to OECD Transfer Pricing Guidelines
On June 19, TEI submitted comments to the OECD regarding the scope of future revisions to Chapters IV and VII of the OECD’s transfer pricing guidelines. TEI’s comments focused on the practical aspects of any future guidance.
TEI Comments on Taxation of Offshore Indirect Transfer
On October 19, TEI submitted comments to the Platform for Collaboration on Tax regarding the Platform’s draft toolkit on the taxation of offshore indirect transfers.
TEI Comments on OECD Request Regarding the Digitalization of the Economy
On October 12, TEI submitted comments to the OECD regarding their request for input on the tax challenges of the digitalization of the economy, including an interim report to be submitted to the G20 finance ministers.