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Aggressive tax planning

Focus

  • Working Party No. 11 was formed in 2013 with responsibility under BEPS project for developing recommendations for Hybrid Mismatch Arrangements (Action 2), Controlled Foreign Companies (Action 3), Interest Deductibility (Action 4) and Mandatory Disclosure (Action 12).

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  • Co-operation and exchange of information on ATP

    The OECD provides a forum for countries to exchange information on tax planning schemes, detection methods and response strategies. The ATP Expert Group is a sub-group of Working Party No.11 that has responsability for maintaining a secure directory of over 400 aggressive tax planning schemes submitted by member countries.

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  • JITSIC

    The Joint International Taskforce on Shared Intelligence and Collaboration brings together 36 of the world's national tax administrations that have committed to more effective and efficient ways to deal with tax avoidance. The JITSIC offers a platform to enable its members to actively collaborate within the legal framework of effective bilateral and multilateral conventions and tax information exchange agreements – sharing their experience, resources and expertise to tackle the issues they face in common.

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OECD's work on tax planning

 

ATP Banner Strings

OECD is at the forefront of efforts to improve international tax co-operation be‌tween governments to counter international tax avoidance and evasion. In furtherance of these goals the OECD set up the ATP Steering Group in 2004 to act as a centre of knowledge and expertise on international  tax planning. The Steering Group began with membership of 7 countries and has now grown to a full working party of 46 OECD and G20 countries. The OECD’s work focuses on identifying trends in international tax planning and helping governments to respond more quickly and effectively to emerging risks. The work is informed by a library of over 400 aggressive tax planning schemes stored on the OECD ATP Directory, a confidential database of schemes maintained by sub-group of countries that are members of WP11.

 

BEPS work

Base erosion and profit shifting (BEPS) refers to tax planning strategies that exploit gaps in the architecture of the international tax system to artificially shift profits to places where there is little or no economic activity or taxation. The CFA has invited Working Party 11 (Aggressive Tax Planning), to carry out the work in relation to 4 of the items under the BEPS Action Plan.

These are:

  • Action 2 on Neutralising the Effects of Hybrid Mismatch Arrangements
  • Action 3 on Strengthening CFC rules
  • Action 4 on Limiting Base Erosion via Interest Deductions and Other Financial Payments
  • Action 12 on Requiring Taxpayers to Disclose their Aggressive Tax Planning Arrangements

 

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