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The Latest onBEPS and Beyondyear-end reviewA review of OECD and country actions in2019 year-end
OverviewThe past year has witnessed major developments in theBEPS project as it moves through the implementationphase, with the result that we are seeing more taxlegislative changes than previously as we kick off 2020.The Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent BEPS, (MLI) entered intoforce on 1 July 2018, with the first MLI modificationsbecoming effective from 1 January 2019. The totalnumber of signatories is 93 as of 1 January 2020 withmany more expected throughout the year.
Crucially, the past year has witnessed the convergenceof the BEPS package and the implementation of theEuropean Union (EU) Anti-Tax Avoidance Directives(ATAD I & II), which has driven a significant increase inthe number of law changes. BEPS measuresincorporated under ATAD I & II including hybridmismatches, controlled foreign company (CFC) rules,exit taxation, a general anti-avoidance rule (GAAR) andinterest deductions are being implemented across notonly EU Member States (MS) but law changes are alsooccurring among non-EU countries.
Based on Action 12 BEPS recommendations, the EUalso adopted Directive 2018/822 (the Directive) on themandatory disclosure and exchange of cross-border taxarrangements on 25 May 2018 under which EU MS mustadopt and publish domestic legislation by 31 December2019. Some MS may require earlier reporting andextend the scope of domestic legislation beyond therequirements of the Directive — for instance, to covervalue-added tax (VAT), domestic arrangements or tointroduce additional hallmarks. As of 1 January 2020,Poland has already adopted the rules (since 1 January2019) and 15 more EU MS have final legislation with 11MS having draft legislation.
The EU Arbitration Directive entered into force on1 July 2019. Its rules aim to improve the resolution oftax disputes and to ensure that disputes related to theinterpretation and application of tax treaties can beresolved more swiftly and effectively.
Moreover, in the period under review both the OECDand the EU continued to roll out their project onaddressing harmful tax practices. To stay off the EUblacklist, many countries fulfilled the requirementsmandated by the EU to: (i) join the OECD/G20 InclusiveFramework (IF) on BEPS; (ii) to meet the globalstandards on exchange of information; and (iii) to adaptdomestic preferential regimes that were deemedpotentially harmful. The latter led to a wave oflegislative changes all around the world.
Our EY team has been reporting on the BEPS Project from its outset. Since 2014, we have tracked BEPS-relateddevelopments, both at the OECD and country level. A summary of each of these BEPS-related developments hasbeen included in our newsletter ”The Latest on BEPS,” and a biannual special edition that highlights andrecapitulates the past six months in review. In the latter half of 2019, ”The Latest on BEPS” Alert was expandedto include, not only reports on recent BEPS-driven activity in individual countries, but also information oncountries’ global and regional policy trends. The first expanded Alert renamed “The Latest on BEPS and Beyond,”was released on 17 September 2019 with a monthly communication issued thereafter. The present report coversthe period 1 July – 31 December 2019.
While the first phase of the BEPS project rapidly movedthrough its implementation phase as the end of 2019approached, the OECD work on the ongoing project underAction 1 entitled “Addressing the Tax Challenges of theDigitalization of the Economy” or BEPS 2.0 is continuingto advance with an ambitious target date of 2020. Workbegan in earnest at the start of 2019 with the firstconsultation document issued in February. Since then wehave seen the OECD issue a Programme of Work, layingout what the IF intended to do for the project and we alsosaw a discussion of the project both in the G20 meetingsthis Summer and in the G7 meetings. As the documentshave evolved (and they have evolved quickly over thepast several months), we have seen the OECD includemore explanation of the rationale for the project andsome elaboration of the proposals in an iterative fashion.Despite the name of the project, the proposal goes wellbeyond the digital economy creating implications for allmultinational businesses.
Finally, a draft toolkit designed to help developingcountries with the implementation of effective transferpricing (TP) documentation requirements was releasedby the partners in the Platform for Collaboration on Taxin September 2019. The Platform aims to release thefinal toolkit in early 2020.
Taken together, these developments show great progresswith more tangible results to come in 2020.
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In recognition of the truly global nature of BEPS,and to continue the development of standards aswell as monitoring the effective implementation ofthe BEPS actions, the OECD and G20 establishedthe OECD/G20 IF on BEPS. With an initialmembership in 2016 of 82 countries andjurisdictions, the OECD/G20 IF has continued toexpand, and now brings together over 135countries and jurisdictions who participate on anequal footing in the development of standards onBEPS-related issues, while also reviewing andmonitoring the implementation of the BEPSpackage including BEPS 2.0.
In 2019, the first aggregated and anonymized datacollected on CbC reports was provided to the OECD forprocessing for statistical purposes. As more databecomes available, a fuller picture may be shown of thecost of tax avoidance and the effects of the BEPSproject. Moreover, this data is used to make impactassessments in relation to the measures proposed underthe OECD project on addressing the challenges of thedigitalization of the economy.
Additional signatures and ratification of the MLI willincrease the implementation of several BEPS Actions,particularly countering treaty shopping under Action 6.This number will increase as more signatories deposittheir instruments of ratification throughout 2020, withthe potential for the MLI to impact up to 3,500 bilateraltax treaties once ratified by all jurisdictions.
In addition, the peer reviews of the BEPS minimumstandards will continue to ensure timely and accurateimplementation and thus safeguard the level playingfield, including the release of the second peer reviewreports relating to compliance by members of the IF onBEPS on Action 6 which is expected in 2020 and a fullschedule of reviews of mutual agreement proceduresunder Action 14.
Also, the ATAD implementation process by many EU MSwill continue with hybrid mismatch rules and EU-specificrules on exit taxation expected to be transposed in2020.
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Looking ahead
The Inclusive Framework
The beginning of the exchange of Country-by-Country (CbC) reports, the continuing exchange ofunilateral tax rulings in combination with theintroduction of new rules to exchange informationon cross-border tax planning schemes to EU MSauthorities under the new EU MandatoryDisclosure Rules (MDR) marks an importantmilestone towards full transparency which is oneof the goals of the BEPS project. Under the EUMDR rules as of 1 July 2020, reporting ofspecifically defined tax arrangements will berequired across all 28 EU MS within 30 days of atriggering event. However, as Poland is the firstadopter of the rules, the 30-day deadline is inforce from January 2019 for all the tax schemesinvolving Poland. Moreover, non-EU jurisdictionsinspired by the EU are following their example. Forexample, Australia, Japan and Mexico, are alsoconsidering the introduction of MDR regimes.
As countries apparently are still not confident thatthe changes in the international tax environmentafter the implementation of the BEPS measures willlead to a sustainable international tax system, thetop priority for the OECD/G20 IF for 2020 is the workon tax and digitalization, which has been takingcenter stage in policy debates as of early 2019. TheIF has made major progress by developing aProgramme of Work and aims to produce aconsensus-based, long-term solution for delivery tothe G20 in 2020. After consultations were held onboth Pillar One regarding a new division of taxingrights for consumer facing businesses and Pillar Twowhich considers a global minimum tax rule, it is goingto be extremely interesting to see what will come outof the meeting of the members of the IF on BEPS atthe end of January 2020. The levels of anticipationgrew even more after recent exchanges of lettersbetween the United States (US) Treasury and theOECD, which started with a letter in which USTreasury asked for a tempering of the ambition levelsof the OECD.
The end of 2019 reflects a flurry of tax policydevelopments as summarized in this report. Many ofthese developments indicate that 2020 will be acrucial year in the design history of the internationaltax system.
The report is structured in the following way. Eachaction is split into two parts. The first part discussesthe OECD developments during the period underreview and identifies the continual guidance and workof the OECD toward the implementation of therelevant measures. The second part includesreferences to specific country developments duringthe final six months of 2019 with respect to eachtopic. This section of the report poses that thecountries are currently adopting new measures in linewith the OECD recommendations and are movingactively toward their implementation. Due to theincreased activity at the EU level, a separate sub-report now addresses the EU BEPS-related activity.
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Digital taxation and BEPS 2.0
Addressing the tax challenges raised by digitalizationhas been one of the top priorities for the OECD/G20 IF in2019. After the delivery of the Interim Report in March2018, the IF continued its work and delivered a PolicyNote in January 2019 including concrete proposals madeby members framed within two complementary pillars:one pillar addressing the broader challenges of thedigitalization of the economy and focusing on theallocation of taxing rights, and a second pillar addressingremaining BEPS concerns by introducing a globalminimum tax rule. Following the Policy Note, the OECDreleased, in February 2019, a public consultationdocument describing the two pillar proposals at a highlevel. They received extensive comments fromstakeholders, and held a public consultation in March2019.
Following the public consultation, in May 2019, theOECD released the “Programme of Work to Develop aConsensus Solution to the Tax Challenges Arising fromthe Digitalisation of the Economy” (the Workplan). Underthe timeline set forth in the Workplan, an outline of thearchitecture of a long-term solution to address thechallenges of the digitalization of the economy is to besubmitted to the IF on BEPS for agreement in January2020 and work will continue to flesh out the policy andtechnical details of the solution throughout 2020 todeliver consensus agreement on new international taxrules by the end of 2020.
Background
For more information, see EY Global Tax Alert, TheOECD takes next step on BEPS 2.0 – Proposal for a“unified approach” for additional market country tax,dated 10 0ctober 2019 and EY Global Tax Alert, OECDhosts public consultation on proposed “unifiedapproach” under Pillar One of BEPS 2.0 project, dated27 November 2019.
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On 9 October 2019, the OECD released a publicconsultation document outlining a proposal from theOECD Secretariat for a “unified approach” under PillarOne (Secretariat Proposal) of the ongoing projecttitled “Addressing the Tax Challenges of theDigitalization of the Economy” (the ConsultationDocument). The Secretariat Proposal provides high-level suggestions on the scope of the new rules beingdeveloped under Pillar One, an approach to the newnexus concept, and an approach for new and revisedprofit allocation rules. More specifically, the scope ofthe Secretariat Proposal for a “unified approach”covers business models for both digitalized as well asnon-digitalized businesses, that are consumer-facing.The Secretariat Proposal includes a new nexusconcept that is not dependent on physical presenceand is largely based on sales. This new nexus isproposed to be separate from the existing permanentestablishment (PE) concept, and it would operateregardless of whether taxpayers have an in-countrymarketing or distribution presence or sell throughrelated or unrelated distributors. In addition, theSecretariat Proposal contains a three-part approachto new and revised profit allocation rules, which wouldprovide a formulaic approach to allocating deemedexcessive profits to market jurisdictions under thenew nexus concept, a formulaic approach for a fixedreturn to baseline marketing and distribution activitiesin situations where there is nexus under existingprinciples, and an approach for allocating additionalprofit to the market jurisdiction based on the arm’s-length principle where the local activities exceed suchbaseline activity. Finally, the Secretariat Proposalcontemplates binding and effective dispute preventionand resolution mechanisms that would cover all threeparts of the profit allocation approach.
Interested parties were invited to submit commentson the consultation document no later than12 November 2019. The OECD then held aconsultation meeting in Paris on 21 and 22 November2019 to give stakeholders an opportunity to discusstheir comments with the IF countries.
The OECD released on 8 November 2019 a publicconsultation document on the Global Anti-Base Erosion(GloBE) proposal under Pillar Two. For purposes of theconsultation, the OECD invited comments on all aspectsof the Workplan on Pillar Two, but specifically requestedcomments on three technical design aspects of theGloBE proposal:
Interested parties were invited to submit writtencomments on the Consultation Document no later than2 December 2019. The OECD then held a consultationmeeting on 9 December 2019 to discuss withstakeholders their comments.
For more information, see EY Global Tax Alert, OECDissues consultation document on technical designaspects of Pillar Two, dated 14 November 2019 and EYGlobal Tax Alert, OECD hosts public consultation onglobal anti-base erosion (GloBE) proposal under PillarTwo of BEPS 2.0 project, dated 13 December 2019.
Developments during the period under review
Pillar One
Pillar Two
1. The use of financial accounts as a starting point fordetermining the tax base under the GloBE proposalas well as different mechanisms to address timingdifferences.
2. The extent to which a group can combine high-taxand low-tax income from different sources takinginto account the relevant taxes on such income indetermining the effective tax rate on such income.
3. The stakeholders’ experience with, and views on,carve-outs and thresholds that may be considered aspart of the GloBE proposal.
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Looking ahead, the Secretariat proposals on both PillarOne and Pillar Two outlined in the consultationdocuments do not represent the consensus view of thejurisdictions participating in the IF but were developedin an effort to facilitate negotiations among countriesso that an agreement can be reached.
The complex issues underlying both the Pillar One andPillar Two proposals will continue to be the subject ofboth policy and technical discussions among the IFjurisdictions through at least 2020. The objective is forthe IF to agree to an outline of the Pillar One work inlate January, endorsing with modifications and furtherdetail the Pillar One proposal for a “unified approach”released by the Secretariat on 9 October. If there is aconsensus within the IF, a public report is expected tobe provided to the G20 finance ministers in lateFebruary, and that report would be subject to commentin the hopes of reaching a final agreement on Pillar Onein July 2020. As for Pillar Two, the OECD is planning torelease another public consultation document by Aprilof 2020 that will expand upon and tie together theissues raised in the 8 November Pillar Two consultationdocument.
The consultation documents underscore that theinternational tax changes being contemplated will haveimplications well beyond digital businesses and digitalbusiness models. These proposals could lead tosignificant changes to the overall international taxrules under which multinational businesses operate andcould have important consequences in terms ofbusinesses’ overall tax liability and countries’ taxrevenues.
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Recognizing the need to address the challenges ofdigitalization, a growing number of jurisdictions assummarized below are taking unilateral actions byintroducing various digital tax measures orinterpretations of the current rules in their domestic law.
The Turkish Parliament enacted Law no.7194introducing the Digital Services Tax (DST) into domesticlegislation on 5 December 2019. The law was publishedin the Official Gazette on 7 December 2019 and will beeffective as of 1 March 2020. The rate of DST is 7.5% onin-scope revenues generated in Turkey by the provisionof certain types of digital services as defined in the law.The DST is imposed on providers of digital services. Itapplies only to companies with global, in-scope revenuesof at least €750 million with revenues of at least 20million Turkish Lira (approximately US$3.3 million) inTurkey from in-scope services. The President isauthorized to reduce the revenue thresholds to as littleas zero or to increase them to up to triple the specifiedlevels and may also reduce the rate to 1% or increase itto 15%, either per type of digital service separately, orfor all types of digital services together.
On 1 January 2020, Austria’s digital tax packageentered into force and includes three key measures: (i)the introduction of a tax on revenue derived from onlineadvertising at a rate of 5%; (ii) an amendment of the VATrules applicable to online purchases of goods sold bythird-country sellers (as of January 2021); and (iii) theintroduction of stricter reporting obligations foroperators of online platforms active in the sharingeconomy.
Also, the Law introducing a DST in France was publishedin the Official Journal in July 2019. The main features ofthe law remain similar to the bill submitted by theGovernment on 6 March 2019. The DST applies at asingle rate of 3% on gross income derived from certaindigital services for which the French Government deemsuser participation is essential for creating value. Onlycompanies with worldwide revenues from taxableservices of €750 million annually and with a total amountof taxable revenues from taxable services obtained inFrance exceeding €25 million annually would be subjectto the tax. A first draft of the administrative guidelineswas published on 16 October 2019 and submitted forpublic consultation until 29 November 2019. The finaldraft should thus be published in the coming months.This first draft mainly includes clarifications on thereporting and accounting obligations, recovery, controland litigation of the DST. The French tax authoritieshave indicated that specific guidelines related to thescope, triggering event, tax base and payment are stillunder preparation.
The final report on Action 15, “Multilateral convention toimplement tax treaty-related measures to preventBEPS,” explores the technical feasibility of an MLI toimplement the treaty-related measures developed duringthe BEPS project and to amend bilateral tax treaties. Tothat end, the MLI was developed and agreed to inNovember 2016 by approximately 100 jurisdictions,including OECD member countries, G20 countries, andother developed and developing countries. Eachprovision under the MLI (Articles 3 to 17) first reflectsthe treaty-related BEPS measures as developed duringthe BEPS project with certain modifications. However,the MLI is structured in a way to provide flexibility forcontracting jurisdictions to implement (parts of) the MLIbased on their needs.
Country-specific developments
BEPS implementationThe MLI
Background
In July 2019, the United Kingdom (UK) also confirmedits intention to introduce a DST to be in place forrevenues arising from 1 April 2020. The UK’s measure istargeted at capturing value generated by certain digitalbusiness models (being search engines, social mediaplatforms and online marketplaces) from their UK user-base. For businesses undertaking the in-scope activities,the revenues derived from UK users will be subject to theDST at 2%. Businesses will only be subject to the DSTwhen the group’s worldwide revenues from in-scopedigital activities are more than £500 million and morethan £25 million of these revenues are derived from UKusers. In addition, there is an allowance of £25 million,which means a group’s first £25 million of revenuesderived from UK users will not be subject to DST. It iscurrently anticipated that businesses who operate at lowprofit margins will be subject to a reduced effective rateof DST, and that loss-making businesses will be exempt.
The current intention is that the UK DST will be amendedas necessary to conform with a multilateral DST if andwhen introduced by the EU, despite the UK no longerbeing a Member State.
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As of 1 January 2020, 93 jurisdictions have signed theMLI. At the time of signature, signatories submitted a listof their tax treaties in force that they designate ascovered tax agreements (CTAs), i.e., to be amendedthrough the MLI. Together with the list of CTAs,signatories also submitted a preliminary list of theirreservations and notifications (MLI positions) in respectof the various provisions of the MLI. The definitive MLIpositions for each jurisdiction will be provided upon thedeposit of its instrument of ratification, acceptance orapproval of the MLI. As of 1 January 2020, 39jurisdictions have deposited their instrument ofratification with the OECD.
Generally, the MLI will enter into force for a jurisdictionon the first day of the month following the expiration of aperiod of three-calendar months beginning on the date ofthe deposit of its instrument of ratification with theOECD. With respect to a specific bilateral tax treaty, themeasures will generally enter into effect after bothparties to the treaty have deposited their instruments ofratification, acceptance or approval of the MLI and aspecified time has passed. The specified time differs fordifferent provisions. The first modifications to bilateraltax treaties on taxed withheld at source entered intoeffect on 1 January 2019.
Country-specific developments
No or only nominal tax jurisdictionsBackgroundIn 2018, the OECD released a standard on substantialactivities that would apply to jurisdictions that do notimpose a corporate income tax. It would also apply tojurisdictions that are considered to impose only nominallevels of corporate income tax to avoid suchrequirements. Broadly, the standard looks at whether aregime encourages purely tax-driven operations orarrangements, as many harmful preferential tax regimesare designed in a way that allows taxpayers to derivebenefits from the regime while engaging in operationsthat are purely tax-driven and involve no substantialactivities.
Development during the period under review
Bosnia and Herzegovina, Jordan, Kenya and Omansigned the MLI during the period under review, bringingthe total number of signatories to 93 as at the date ofthis report.
The MLI entered into force for an additional 12jurisdictions during the period under review, beingCuracao, Georgia and the Netherlands (1 July 2019),Luxembourg (1 August 2019), United Arab Emirates(1 September 2019), Belgium, India, Russia (1 October2019), Norway (1 November 2019), Canada, Switzerlandand Ukraine (1 December 2019). Canada, Denmark,Iceland, Latvia, Liechtenstein, Mauritius, Norway, Qatar,Switzerland and Ukraine deposited their instruments ofratification with the OECD during the period underreview. The MLI entered into force for Denmark andIceland on 1 January 2020, will enter into force forLatvia and Mauritius on 1 February 2020 and forLiechtenstein and Qatar on 1 April 2020.
Many other jurisdictions have taken steps domesticallyfor the ratification process of the MLI, such as CostaRica, Portugal, and Uruguay.
Development during the period under reviewAfter agreeing on the substantial activities’ standard, inJuly 2019 the OECD’s Forum on Harmful Tax Practices(FHTP) identified 12 jurisdictions as being No or onlynominal tax jurisdictions, namely Anguilla, the Bahamas,Bahrain, Barbados, Bermuda, British Virgin Islands,Cayman Islands, Guernsey, Isle of Man, Jersey, Turks andCaicos Islands and the United Arab Emirates (UAE).According to the FHTP, the domestic legal framework ofall of these jurisdictions, except for the UAE, are in linewith the substantial activities standard and are therefore“not harmful.” Regarding the UAE, it was concluded thatits legal framework was generally in line with the standard,with one technical point outstanding. In this respect, theUAE committed to make further legislative changes andthe law is now “in the process of being amended.”
For more information, see EY Global Tax Alert, OECDreleases update on peer review of preferential tax regimesand no or only nominal tax jurisdictions, dated 24 July2019.
On 31 October 2019, the OECD released new guidancetitled, “Substantial Activities in No or Only Nominal TaxJurisdictions: Guidance for the Spontaneous Exchange ofInformation.” The Guidance addresses the practicalmodalities regarding the exchange of informationrequirements of the substantial activities requirement forno or only nominal tax jurisdictions. It provides guidanceon the timelines for the exchanges, the international legalframework under which they may occur and clarificationson the key definitions, in order to ensure that thespontaneous exchanges take place in a coordinated andefficient manner. The guidance also contains astandardized IT format for the spontaneous exchanges,the No or only nominal Tax Jurisdictions (NTJ) XMLSchema and the related user guide.
For more information, see EY Global Tax Alert, OECDreleases additional guidance on spontaneous exchange ofinformation by no or only nominal tax jurisdictions, dated7 November 2019.
Also, during the period under review, the OECD updatedthe existing guidance on the implementation of CbCR(for the 10th time). In November 2019, the OECDupdated the guidance to include questions and answerson, among other topics, treatment of dividends, thedeemed listing provision, accounting periods other than12 months, the requirements for and operation of localfiling, the use of rounded amounts and the informationthat must be provided with respect to the sources ofdata used. The OECD also published a summary ofcommon errors made by MNE groups in preparing CbCreports. The release of this summary aims at helpingMNE groups in avoiding these errors and taxadministrations in detecting them when they occur.
For more information, see EY Global Tax Alert, OECDreleases additional guidance on Country-by-CountryReporting and a summary of common errors made byMNE Groups in preparing these reports, dated7 November 2019.
In December 2019, the OECD updated once again theexisting guidance to make clear that, under the BEPSAction 13 minimum standard, the automatic exchange ofCbC reports filed under local filing rules is not intended.The OECD also posted a summary of CbCR notificationrequirements in IF member jurisdictions aimed atassisting MNE groups in complying with notificationrequirements in the different jurisdictions where theyhave constituent entities. The summary includesinformation on 89 jurisdictions, out of which 69 have anotification requirement in place.
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On 5 October 2015, the OECD released its final report onAction 13, “Transfer Pricing Documentation andCountry-by-Country Reporting,” under its BEPS ActionPlan. The report introduced a standardized three-tieredapproach to transfer pricing documentation formultinational enterprises (MNEs) consisting of a masterfile, a local file, and a CbC report. To give greatercertainty to tax administrations and MNE groups on theimplementation and operation of CbCR rules, the OECDissued additional guidance in June 2016 and hasupdated the guidance nine times since then. The OECDhas also released other materials to support countriesintroducing CbCR. For example, in September 2017, theOECD issued two handbooks (one on the effectiveimplementation of CbCR and another on effective taxrisk assessment), and a report on the appropriate use ofinformation contained in CbC reports.
Developments during the period under reviewCbCR continues to play a key role in promotingtransparency and accuracy in reporting to taxauthorities. As of 1 January 2020, more than 85jurisdictions have law in place introducing a CbCRobligation. This means that substantially every MNE withconsolidated group revenue of at least €750 million isalready required to file a CbC report. For an overview ofthe Action 13 implementation, visit our EY website.
During the second half of 2019, the OECD releasedadditional exchange relationships that have beenactivated under the CbC Multilateral CompetentAuthority Agreement (CbC MCAA). Also, Bahrein, BritishVirgin Islands, Saudi Arabia, Seychelles and Tunisia wereadded to the list of signatories of the CbC MCAA duringthe period under review.
As of 1 January 2020, together with the exchangerelationships under the EU Council Directive2016/881/EU and the bilateral competent authorityagreements for exchanges under Double TaxConventions or Tax Information Exchange Agreements,there are over 2,400 automatic exchange relationshipsestablished among jurisdictions committed toexchanging CbC reports. This also includes 45 bilateralagreements with the US. The list of automatic exchangerelationships that have been activated is available on theOECD website.
Country-specific developmentsDuring the period under review, countries andjurisdictions have continued to amend their domesticlegislation and publish guidance to introduce and/orfurther enhance CbCR compliance.
The Tunisian Minister of Finance issued a decision thatintroduces master file and local file requirements inTunisia. According to the decision, a master file and localfile must be maintained by every Tunisian entity fortransactions occurring on or after 1 January 2020 if itsannual gross turnover exceeding TND20 million(approximately US$7 million). The master file and localfile should be submitted to the tax authority uponrequest at the commencement of an advanced tax auditprocedure.
Action 13 including CbC Reporting(CbCR)Background
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Also, on 23 December 2019, the OECD released the 2018peer review report relating to the compliance by membersof the IF on BEPS of the minimum standard on Action 5for the compulsory spontaneous exchange on certain taxrulings (the transparency framework) for the 2018calendar-year period. This is the third annual peer reviewof the transparency framework. It covers individualreports for 112 jurisdictions, including 20 jurisdictionsreviewed for the first time. As one of the majorconclusions, it was noted that until 31 December 2018more than 18,000 tax rulings had been identified andalmost 30,000 exchanges of information have taken placeto date. The report concludes that 68 jurisdictions havenow successfully implemented the standard and did notreceive any recommendations for improvement. For therest of the assessed jurisdictions, the report contains 52jurisdiction-specific recommendations on issues such asimproving the timeliness of the exchange of informationand ensuring that exchanges of information are made withrespect to preferential tax regimes that apply to incomefrom intellectual property.
At the end of August 2019, a draft bill wassubmitted to the Ukrainian Parliament implementingthe BEPS action plan recommendations into theUkrainian Tax Code, including the introduction of thethree-tiered TP documentation – local file, masterfile and CbC report. On 16 January, this draft billwas approved by the Parliament in the final readingand now awaits the President’s signature.
The Greek Public Revenue Authority published inSeptember 2019 circular No. 1341 which providesguidance regarding the timing and procedure offiling of the CbC reports and notifications in Greece.In Belgium, the Federal Public Service Financepublished updated guidelines on the process forfiling corrective CbC reports.
Recognizing that the key element is the monitoringof implementation, members of the IF on BEPSdeveloped a monitoring process for the BEPSproject that aims to ensure that all members complywith the BEPS minimum standards, i.e., BEPSrecommendations that all members of the IF onBEPS have committed to implement, and refer tosome of the elements of Action 5 on harmful taxpractices, Action 6 on treaty abuse, Action 13 on TPdocumentation and CbCR and Action 14 on disputeresolution. Accordingly, each BEPS member issubject to an ongoing peer review process to ensuretimely and consistent implementation of the fourminimum standards.
Peer reviews
The first peer review report relating to the compliance bymembers of the IF on BEPS to the minimum standard onBEPS Action 6 for the prevention of treaty abuse wasreleased in February 2019. The report covered 116jurisdictions and information available as of 30 June2018.
For more information, see EY Global Tax Alert, OECDreleases first annual peer review report on BEPS Action 6,dated 15 February 2019.
The next peer review has been launched in the first half of2019 and it is expected to be released in early 2020.
Action 5On 23 July 2019, the OECD released an update onthe results of the peer reviews of jurisdictions’domestic laws under BEPS Action 5. The updatedresults cover 56 regimes, bringing the number ofregimes that have been reviewed, or are underreview, to 287. The assessments were undertakenby the OECD FHTP. The update is an indication ofthe extent of the ongoing work aimed at endingharmful tax practices, through the requirement thatall preferential regimes require adequate levels ofsubstance. The peer review results will continue tobe updated from time to time, as approved by the IFon BEPS.
For more information, see EY Global Tax Alert,OECD releases update on peer review of preferentialtax regimes and no or only nominal tax jurisdictions,dated 24 July 2019.
Action 6
Action 13
The peer review of the Action 13 minimum standard isproceeding in stages with three annual reviews in 2017,2018 and 2019 on different aspects of the three keyareas under review: (i) the domestic legal andadministrative framework, (ii) the exchange of informationframework, and (iii) the confidentiality and appropriateuse of CbC reports.
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On 3 September 2019, the OECD released thecompilation of outcomes of the second phase ofpeer reviews of the minimum standard on Action13 of the BEPS project. According to theCompilation, over 80 jurisdictions have alreadyintroduced legislation to impose a filing obligationfor CbCR on MNE groups, covering almost all MNEgroups with consolidated group revenue equal toor exceeding €750 million. Where legislation is inplace, the implementation of CbCR has beenfound to be largely consistent with the Action 13minimum standard. However, 41 jurisdictionshave received a general recommendation toeither put in place or finalize their domestic legalor administrative framework, and 17 jurisdictionsreceived one or more recommendations to makeimprovements to specific areas of theirframework.
The next annual peer review (phase three) waslaunched in July 2019 and will aim to review allthe jurisdictions participating in the OECD’s IF,focusing on progress made by jurisdictions toaddress recommendations in the phase two peerreport.
For more information, see EY Global Tax Alert,OECD releases outcomes of the second phase ofpeer reviews on BEPS Action 13 and announcespublic consultation, dated 9 September 2019.
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The peer review under Action 14 is being undertaken intwo stages. In Stage 1, a review is conducted of how aBEPS IF member implements the minimum standardbased on its legal framework for Mutual AgreementProcedures (MAPs) and how it applies the framework inpractice. In Stage 2, a review is conducted of themeasures the BEPS IF member takes to address anyshortcomings identified in Stage 1 of the peer review.
During the period under review, the OECD has releasedthe Stage 1 peer review reports on the implementationof the BEPS minimum standard on Action 14 for thesixth and seventh batch of jurisdictions (i.e., Argentina,Chile, Colombia, Croatia, India, Latvia, Lithuania andSouth Africa are in the sixth batch and Brazil, Bulgaria,Mainland China and Hong Kong SAR, Indonesia, Russia,and Saudi Arabia are in the seventh batch). Overall, thereports conclude that five of the eight assessedjurisdictions in the sixth batch meet the majority ormost of the elements of the Action 14 minimumstandard. Latvia meets slightly more than half of theelements of the Action 14 minimum standard, and Indiameets half of the elements. Colombia meets fewer thanhalf of the elements of the Action 14 minimumstandard. On the seventh batch, five of the sevenassessed jurisdictions meet the majority or most of theelements of the Action 14 minimum standard. Russiameets half of the elements of the Action 14 minimumstandard, and Saudi Arabia meets less than half of theelements.
For more information, see EY Global Tax Alert, OECDreleases sixth batch of peer review reports on Action14, dated 25 October 2019 and EY Global Tax Alert,OECD releases seventh batch of peer review reports onBEPS Action 14, dated 3 December 2019.
Also, during the second half of 2019, the OECDreleased the first batch of Stage 2 peer review reportsrelating to the outcome of the peer monitoring of theimplementation by Belgium, Canada, Netherlands,Switzerland, UK and the US (the batch 1 jurisdictions)of the BEPS minimum standard on dispute resolutionunder Action 14. Stage 2 focuses on monitoring thefollow-up of any recommendations that resulted fromthe batch 1 jurisdiction’s Stage 1 peer review reportsthat were released on 26 September 2017. Wheredeficiencies were identified, the Stage 2 monitoringshowed that the jurisdictions have worked to addressthem. The Stage 2 reports for the batch 1 jurisdictionsconclude that the majority of these jurisdictions haveaddressed almost all or most of the identifieddeficiencies.
During the second half of 2019, non-EU jurisdictionsreleased significant domestic tax reforms includingnumerous tax law changes aimed at strengthening taxcompliance and challenging perceived BEPS activities.The changes impose additional compliance obligations onmultinationals and may impact certain intercompanytransactions. The tax reforms will significantly changethose jurisdictions’ tax landscape for businesses withoperations there.
For more information, see EY Global Tax Alert, OECDreleases first batch of Stage 2 peer review reports ondispute resolution, dated 14 August 2019.
Significant domestic reforms inInternational Taxation
Action 14
MexicoMexico enacted the final economic package (the Reform)through publication in the Official Gazette of 9 December2019. President Lopez Obrador signed the Reform on6 December 2019.
Among others, the major tax reform changes include:
• Expansion of the PE concept in the Mexican IncomeTax Law so it aligns with the recommendations ofBEPS Action 7, and the provisions of Articles 12-15 ofthe MLI.
• Introduction of new anti-hybrid rules for entities orlegal arrangements treated as fiscally transparentunder foreign tax regulations. Absent a tax treaty, thenew rules would treat foreign fiscally transparententities and legal arrangements as separate taxpayers(legal entities) for Mexican income tax purposes.
• Amendment of the VAT Law to require digital serviceproviders to collect VAT on the sale of certain goodsand services in Mexico. It would also require incometax withholding on certain transactions with Mexicanindividuals.
• Expansion of the GAAR and the potentialrecharacterization of business transactions if theMexican tax authorities determine that they lackbusiness purpose.
• Introduction of new mandatory disclosurerequirements for reportable transactions. The law lists14 characteristics that would lead to a transactionbeing reportable if a Mexican resident or nonresidentobtains a tax benefit in Mexico directly or indirectly. Ingeneral, the disclosure requirements will be effective1 January 2021 and will apply to reportabletransactions for which the tax benefit is obtained after1 January 2020.
The Latest on BEPS and Beyond – 2019 year-end review 13
• Restriction of deductions of any payments, includingthose for the cost of goods sold, to related partyresidents in a low tax jurisdiction. In general terms,a jurisdiction is considered as low-tax when an entityis subject to an effective tax rate of less than 22.5%,inclusive of state and local taxes that are deemed tobe income taxes. This provision applies to paymentsmade directly to the related party or through astructured agreement.
• Limitation on businesses with more thanMxP$20 million of net interest expense each year toa net interest deduction limitation equal to 30% of“adjusted taxable income,” defined similarly toearnings before interest, taxes, depreciation andamortization (EBITDA). Businesses may carryforward any non-deductible interest expense for10 years.
Most of the Reform will be effective 1 January 2020,with exceptions for the digital services rules andcertain rules on fiscally transparent entities, whichhave their own effective dates.
For more information, see EY Global Tax Alert, Mexicoenacts significant tax reform: Measures for businessesto consider, dated 10 December 2019.
Over the past several years, the EU has adopted a numberof the OECD’s anti-BEPS measures on an EU-wide basiswith a view to addressing multinational tax avoidancepractices via hard law measures.
The past year has seen significant advances in theimplementation by EU MS of the BEPS Actions, with theadoption of legally binding anti-tax avoidance measurestargeting hybrid mismatches (Action 2), CFCs (Action 3)and interest deductions (Action 4), with added EU-specificrules on exit taxation and a GAAR. These measures havestarted to be implemented in 2019 and will be phased inthrough 2022 with the EU and OECD both discussingfurther options to fight perceived under taxation of digitalbusiness models (Action 1).
In addition, all 28 EU MS have signed the MLI and are inthe process of transposing the new EU MandatoryDisclosure Directive leading to the reporting of cross-border reportable arrangements as of July 2020(automatic exchange of information regarding reportablecross-border arrangements for tax intermediaries and taxpayers) into national legislation by the end of 2020.
Due to the increased activity at the EU level, this separatesub-report specifically addresses the EU BEPS-relatedactivity.Chile
On 22 August 2019, the Chilean House ofRepresentatives approved a tax reform bill after oneyear of debate and political negotiation. The discussionat the Senate has been impacted by social demands andhas involved several amendments to the bill initiallyapproved by the House of Representatives. Discussion inthe Senate is expected to finalize within January 2020.
Under the current version of the tax bill, some of themajor measures that would be introduced are:
• Establishment of a 10% tax rate on digital servicesprovided by nonresidents to Chilean individuals(independent of where servers may be located). Thetax would apply to digital brokering services, digitalcontent entertainment (either downloadable,streaming or other technology), advertising services(to be used abroad), use of and subscription toplatform and technological services and storageservices (cloud or software services).
• Definition of PE based on the criteria set forth byBEPS Action 7 (notwithstanding the definition setforth in current tax treaties).
For more information, see EY Global Tax Alert, ChileanHouse of Representatives approves tax reform bill, dated13 September 2019.
EU BEPS-related developments
ATADThe EU ATAD I & II form part of a larger anti-tax avoidancepackage adopted by the EU in response to the OECD’sBEPS action plan.
Designed to tackle tax avoidance practices, ATAD I & II setforth minimum standards for EU MS, requiring them tochange their corporate tax laws in certain areas namely;interest deductibility limitation, a GAAR, CFC rules, exittaxation and hybrid mismatches within specifictimeframes.
MS may go beyond the minimum standards provided in theDirectives, keep existing rules in targeted areas if they aredeemed compliant with the ATAD provisions, or amendthem to integrate the ATAD standards. For somemeasures, there are also derogations provided, which mayor may not be used. Therefore, a wide range ofimplementation choices are available to MS and as thedeadline for ATAD implementation approaches, all eyesare on MS and their chosen policies.
The Latest on BEPS and Beyond – 2019 year-end review 14
Country-specific developments
As of 1 January 2020, the majority of EU MS have noweither amended their existing domestic rules orimplemented new rules to meet the ATAD standard inrespect of CFC rules. During the period under review,changes were proposed by Denmark and Germany toupdate their existing domestic CFC laws to bring theirlaws more in line with the ATAD I.
Bulgaria, Cyprus, Estonia, Finland, France, Ireland,Luxembourg, Netherlands, Poland and Slovenia have alleither proposed and/or adopted rules to cover theimplementation of the Council Directive (EU) 2017/952amending EU Directive 2016/1164, regarding hybridmismatches with third countries (ATAD II) during thelatter half of 2019. The long-expected draft of theGerman anti-hybrid rules was also issued in December2019. The French finance bill for 2020 published onDecember 29, 2019 literally transposes into Frenchdomestic law the anti-hybrid provisions provided byATAD I and ATAD II.
Additionally, Bulgaria, Finland, Slovenia have introducedrules to adopt the Exit tax rules.
As of 1 January 2020, several countries still need toamend their existing domestic rules to meet theATAD I & II standards in respect of their Exit Tax andhybrid mismatch rules.
Finally, activity on interest limitations was almostexclusively occurring among non-EU MS in the latter halfof 2019, indicating that the majority of Europe hasalready previously implemented either BEPS Action 4 orthis part of the ATAD I. Austria is expected to implementnew rules on interest limitations prior to 2024 to alignwith the ATAD I (discussion with Commission ongoing).Ireland is also expected to implement new rules oninterest limitations with effect from 1 January 2021.
In the annex of this sub-report there is a chart listing theEU MS, noting whether the state’s domestic rules meetthe ATAD requirements and whether the state hasimplemented the relevant rules. The chart illustratessome high-level information on the rules in each MS.
Mandatory Disclosure Rules (MDR)The EU adopted Directive 2018/822 (the Directive)on the mandatory disclosure and exchange of cross-border tax arrangements on 25 May 2018.
The Directive, which is the sixth update of theDirective 2011/16/EU on Administrative Cooperationand therefore commonly referred to as DAC6, isaimed at improving transparency and addressingaggressive cross-border tax planning. It broadlyreflects the objectives of Action 12 (MandatoryDisclosure Rules) of the BEPS project, as well asintroducing automatic exchanges of the disclosuresacross the EU MS.
Under DAC6, there is an obligation for intermediariesand taxpayers with an EU nexus to disclose any cross-border arrangement that falls within one or more ofthe hallmarks. These hallmarks target a relativelywide range of cross-border structures andtransactions, including certain deductible paymentswhich are taxed at a rate of zero or nearly zero whenreceived, and intercompany transactions which meetspecific transfer pricing hallmarks, such as anytransfer of hard-to-value intangibles. Under theDirective, there are no minimum thresholdexceptions. However, some of the hallmarks will onlytrigger reporting requirements when they also fulfillthe main benefit test.
Cross-border reportable arrangements, where thefirst step of implementation is taken during thetransitional period between 25 June 2018 and30 June 2020, are required to be reported by31 August 2020. As of 1 July 2020, reporting will berequired within 30 days of a triggering event, e.g.,the cross-border arrangement being ready forimplementation.
EU MS were required to adopt and publish domesticlegislation implementing DAC6 by 31 December 2019.DAC6 sets out a minimum standard however each MScan take further measures; for example: (i) introducereporting obligations for purely domesticarrangements; (ii) extend the scope of taxes covered;(iii) bring forward the start date for reporting. Whilemany MS have broadly aligned their domestic rules tothe Directive others like Poland and more recentlyPortugal have deviated.
See EY Global Tax Alert, EU publishes Directive onnew mandatory transparency rules for intermediariesand taxpayers, dated 5 June 2018.
The Latest on BEPS and Beyond – 2019 year-end review 15
As of 1 January 2020, the status of the EU MDR localcountry implementation is as follows:
Country-specific developmentsDuring the period under review Austria, Belgium, Croatia,Denmark, Estonia, Finland, France, Germany, Ireland,Hungary, Lithuania, Malta, Netherlands and Slovakia allpassed bills to implement MDR in their domestic laws whichwill require taxpayers and intermediaries to report cross-border reportable arrangements from 1 July 2020.
While the final country MDR legislation in theaforementioned MS is broadly aligned to the requirementsof the Directive, most countries have yet to publishexplanatory notes or official guidance on the application ofthese rules. Detailed regulations and guidance should beclosely monitored in respect of all EU MS, to determine theextent to which national legislation will fully align with therequirements of the Directive and importantly to assesswhere national legislation deviates in the context of thescope of taxes covered, the content of the hallmarks, theprocedures for disclosure and the penalty regime forfailures to report.
In July 2019, the UK published its draft MDR regulations,which follow the EU requirements closely. These areincluded in the International Tax Enforcement (DisclosableArrangements) Regulations 2020. Furthermore, the UKGovernment has published a note which provides furtherclarification on its draft regulations and details the impact.
The Dutch Government also published a Q&A documentproviding further clarification on its draft legislation toimplement DAC6 in its domestic legislation.
You can access relevant information about the EU MDR, EYGlobal Tax Alerts and details relating to our MDR Web tooland tax advisory services via our Global MDR website.
EU black list and harmful regimesOn 5 December 2017, the Council of the EU (theCouncil) published a listing of “uncooperativejurisdictions for tax purposes” (EU black list),comprising 17 jurisdictions that were deemed to havefailed to meet relevant criteria established by theEuropean Commission. The listing criteria are focusedon three main categories: tax transparency, fairtaxation and implementation of anti-BEPS measures.
On 25 November 2019, the Council published a reportfrom the Code of Conduct Group (COCG) (the report)that encompasses the work of the COCG during thesecond half of 2019 under the Finnish Presidency of theCouncil. Among other issues, the report includes adetailed state of play on the EU list of non-cooperativejurisdictions for tax purposes.
During the period under review, a number of changeswere made to the EU list as territories were removeddue to findings that they are now compliant withcommitments on tax cooperation ahead of setdeadlines. Currently there are 8 jurisdictions included inannex I (the so-called black list) of non-cooperativejurisdictions for tax purposes out of the 17 initiallyannounced on 5 December 2017. These are AmericanSamoa, Fiji, Guam, Oman, Samoa, Trinidad and Tobago,US Virgin Islands and Vanuatu.
There are 17 territories remaining on Annex II (referredto as the gray list) after the European Council endorsedthat, Jordan having, on 29 October 2019, joined theGlobal Forum on transparency and exchange ofinformation for tax purposes and the IF on BEPS, shouldbe removed from sections 1.2 and 3.1 of Annex II.
The report also includes new guidance, namely onnotional interest deductions regimes, treatment ofpartnerships under criterion 2.2 (existence of taxregimes that facilitate offshore structures which attractprofits without real economic activity) for screeningjurisdictions, and on defensive measures towards non-cooperative jurisdictions. In addition, the reportincludes a list of new preferential regimes that theCOCG has identified for review. This includes foreignsource income exemption regimes that will be reviewedin 2020, based on the guidance issued in October 2019.
• In force: Poland (since 1 January 2019)
• Final legislation: 15 MS (Austria, Belgium, Croatia,Denmark, Estonia, Finland, France, Germany, Hungary,Ireland, Lithuania, Malta, Netherlands, Slovakia, andSlovenia)
• Draft legislation: 11 MS (Bulgaria, Cyprus, CzechRepublic, Italy, Latvia, Luxembourg, Portugal, Romania,Spain, Sweden, and the UK)
• No activity reported: Greece
The Latest on BEPS and Beyond – 2019 year-end review 16
Even though the COCG started outside of the EU legalinfrastructure as a political peer pressure group amongthe MS, and had no legally binding consequences, itcontinues to play an increasingly important role, and iswidely accepted and supported by the EuropeanCommission. The reports, findings, guidance,recommendations and standard-setting work of thegroup should therefore be closely monitored bybusinesses with operations in any of the jurisdictionsremaining on the so-called black lists now and in thefuture.
For more information, see EY Global Tax Alert, EU Codeof Conduct Group issues update report, including newguidance, dated 12 December 2019.
CbCR status in the EUThe European Commission proposed in 2016 to amendthe Accounting Directive (Directive 2013/34/EU). Theproposal built upon BEPS Action 13, however, it went astep further, requiring large MNEs and stand-aloneundertakings operating in the EU to draw up and publicly(on the website of the MNE or undertaking) to discloseincome tax information, including a breakdown of profits,revenues, taxes and employees.
At the EU Competitiveness Council (COMPET) meetingon 28 November 2019, ministers representing the 28current EU MS failed to reach agreement, in a majorityvote, on whether tax and financial information containedwithin CbC reports should be made available to thepublic. Of the MS, 14 (Belgium, Bulgaria, Denmark,Finland, France, Greece, Italy, Lithuania, Netherlands,Poland, Portugal, Romania, Slovakia, and Spain) voted infavor of the proposal, while 12 (Austria, Croatia, Cyprus,Czech Republic, Estonia, Hungary, Ireland, Latvia,Luxembourg, Malta, Slovenia, and Sweden) votedagainst. Germany abstained, while the UK failed to vote.As a result of the vote, amendments to the Directive willnot be passed into law. It may, however, be revised andput forward to COMPET for approval a second time.
For more information, see EY Global Tax Alert, EU:Public CbCR fails to move forward in latest Europeanvote, dated 4 December 2019.
Annex
ATADimplementationoverview as of15January 2020
The Latest on BEPS and Beyond – 2019 year-end review
Country Name Email
Austria Patrick PlanskyNina Peinsipp
[email protected]@at.ey.com
Belgium Jean-Charles van HeurckMieke Van Vlasselaer
[email protected]@ey.com
Bulgaria Viktor I MitevPetyo Stoykov
[email protected]@bg.ey.com
Chile Juan P Navarrete PobleteMariela Gonzalez
[email protected]@ey.com
Croatia Masa SaricTamara Korkutovic
[email protected]@hr.ey.com
Cyprus Eleni Papachristodoulou [email protected]
Czech Republic Jakub Majer [email protected]
Denmark Malte Soegaard [email protected]
Estonia Ranno Tingas [email protected]
Finland Laura Lahdenperä [email protected]
France Frederic VallatMathieu Pinon
[email protected]@ey.com
Germany Tobias Appl [email protected]
Greece Spyros KaminarisEleanna Kamperi
[email protected]@gr.ey.com
Hungary Gabor Kiss [email protected]
Ireland Micheal Bruen [email protected]
Italy Emiliano Zanotti [email protected]
Latvia Sandra Usane [email protected]
Lithuania Agne Meidute [email protected]
Luxembourg Serge HuysmansXavier Picha
[email protected]@ey.com
Malta Miraine Falzon [email protected]
Mexico Enrique Perez Grovas [email protected]
Netherlands Simone AdmiraalTim Clappers
[email protected]@ey.com
Poland Sylwia MigdalJoanna Pachnik
[email protected]@ey.com
Portugal Rita F VazValentin Cretu
[email protected]@ro.ey.com
Romania Cyril ChovanecIvana Klukova
[email protected]@sk.ey.com
Slovakia Lucijan Klemencic [email protected]
Spain Isabel Hidalgo Galache [email protected]
Sweden Tonie Persson [email protected]
Tunisia Faez Choyakh [email protected]
Turkey Ates KoncaEzgi Boz
[email protected]@tr.ey.com
Ukraine Igor O Chufarov [email protected]
UK Graham J ShawBlaise Dowell
[email protected]@uk.ey.com
Contact List 18The Latest on BEPS and Beyond – 2019 year-end review
The Latest on BEPS and Beyond – 2019 year-end review
For additional information with respect to thispublication, please contact the following:
Ernst & Young LLPGlobal Tax Desk NetworkNew York
Gerrit [email protected]
Jose A. (Jano) [email protected]
Marlies de [email protected]
The Latest on BEPS and Beyond – 2019 year-end review
David Corredor-Velá[email protected]
Ernst & YoungBelastingadviseurs LLPAmsterdam
Konstantina [email protected]
Ernst & YoungBelastingadviseurs LLPRotterdam
Ernst & YoungGDS India
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