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The Austrian CIT Act already provides for a provision on non-deductibility of interest payments to related parties which are subject to no or low taxation. Additionally, interest payments on debt incurred in course of acquiring shares BEPS Action 4 makes recommendations on best practices in the design of rules to address base erosion and profit shifting (BEPS) using interest and other economically equivalent payments. The recommendation made in 2015 is to align interest deductions with taxable economic activity. The focus of Action 4 is on the use of debt to achieve excessive the Base Erosion Profit Shifting (BEPS) Action Plan 4 (AP 4) states that the use of interest is one of the simplest profit-shifting techniques available in international tax planning. The fluidity and fungibility of money makes it a relatively simple exercise to adjust the mix of debt and equity in an entity. The Action Item 4: Interest Deductions Summary Limiting Base Erosion Involving Interest Deductions and Other Financial Payments – common approaches based on best practices for preventing base erosion through the use of interest expense. Action 4 of the BEPS plan addresses perceived harmful use of financing arrangements to shift the location of profits to jurisdictions with low effective rates of taxation.

Executive summary. On 28 November 2019, the Organisation for Economic Co-operation and Development (OECD) released the seventh batch of peer review reports relating to the implementation of the Base Erosion and Profit Shifting (BEPS) minimum standard under Action 14 on improving tax dispute resolution mechanisms. 1 Brazil was among the assessed jurisdictions in the seventh batch. 2 Action 11: Establish methodologies to collect and analyse data on BEPS and the actions to address it Normalised score where 0 = low importance for all; 100 = high importance for all Action 2: Neutralise the effects of hybrid mismatch arrangements Action 3: Strengthen CFC rules Action 13: Re-examine transfer pricing documentation Taxation is at the core of countries' sovereignty, but in recent years, multinational companies have avoided taxation in their home countries by pushing activities abroad to low or no tax jurisdictions. The G20 asked OECD to address this growing problem by creating this action plan to address base erosion and profit shifting.

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The best practice approach that is recommended by BEPS Action 4 is a combination of the approaches listed under 4, 5 and 6 above. 2015-10-06 BEPS Action 5. Counter harmful tax practices more effectively, taking into account transparency and substance. The Federal Act on Tax Reform and AHV Financing (TRAF), which entered into force on 1 January 2020, abolished tax regimes that were no longer internationally recognised and introduced new, internationally accepted rules.; The spontaneous exchange of information on advance tax rulings Summary/Action This note contains additional comments received with respect to the public discussion draft on BEPS Action 4 (Interest Deductions and Other Financial Payments).

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Limit base erosion via interest deductions and other financial payments.

Country-by-Country Reporting: Country implementation summary read.kpmg.us/global-tax-reform Key: Implemented draft bills Intentions to Implement No Development Total Count: 75 Countries 4 Countries 8 Countries • Panama • Rwanda • Trinidad & Tobago • Ukraine • Uganda On October 5, 2015 the OECD has published the final package of the BEPS Actions and on October 8, 2015 the G20 has approved Action 7. The particular focus of Action 7 is the artificial avoidance of the permanent establishment (hereinafter ”PE”) status by tax-motivated constructions. Executive summary. On 15 December 2020, the Organisation for Economic Co-operation and Development (OECD) released the fourth annual peer review report (the report) relating to compliance by members of the Inclusive Framework on Base Erosion and Profit Shifting (BEPS) with the minimum standard on BEPS Action 5 for the compulsory spontaneous exchange of certain tax rulings (the transparency Restrictions on interest deductions are vexing multinational group tax planning.
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There is an obligation to implement (minimum standards) with regard to combating harmful tax practices and the spontaneous exchange of information on advance tax rulings (Action 5), the inclusion of abuse clauses in double taxation agreements (Action 6), country-by-country reporting (Action 13) and the dispute resolution mechanisms (Action 14). follow BEPS (Action 4) directives. Implementing regulations are still pending. The Austrian CIT Act already provides for a provision on non-deductibility of interest payments to related parties which are subject to no or low taxation. Additionally, interest payments on debt incurred in course of acquiring shares BEPS Action 4 makes recommendations on best practices in the design of rules to address base erosion and profit shifting (BEPS) using interest and other economically equivalent payments.

Some measures can be used immediately, others require renegotiating bilateral tax treaties . Country-by-Country Reporting: Country implementation summary read.kpmg.us/global-tax-reform Key: Implemented Draft bills Intentions to implement No development Total Count: 76 Countries 4 Countries 8 Countries • Namibia • Panama • Rwanda • Trinidad & Tobago • Ukraine • Uganda 2014-09-16 2019-09-09 BEPS Action 4 in the UK The draft legislation: A summary. Key points of note: — Confirmed some areas that have changed following consultation responses — Included the first details on the administrative and compliance process — Not yet complete, BEPS Action 13: Country implementation summary (1) Dates provided as an example for an entity with December 31st fiscal year end. (2) If a CbyC effective date is listed and filing date is BLANK, please see the Country Detail tab to determine the first filing deadline.
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A final report on Action 4, which was published as part of the OECD’s 5 October 2015 package of final reports, includes recommendations for domestic rules to restrict interest deductions by reference to a proportion of the profits of an entity or group.

B. SUMMARY OF BEPS & ITS ACTION PLANS 3 B. 1. Introduction to BEPS 3 B. 2.