Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 4.

The 2015 Report on BEPS Action 4 established a common approach which directly links an entity’s net interest deductions to its level of economic activity, based on taxable EBITDA. Further work on two aspects of the common approach was completed in 2016 and this is included in this update.

This book provides a comprehensive analysis of current techniques for profit shifting and tax base erosion in the area of corporate taxation and measurement. Firstly, it explains the relevance of the issue at hand – profit shifting and base erosion in the context of the 21st century. In turn, the book provides a comprehensive analysis of available techniques for the identification and measurement of profit shifting and base erosion, which adopt both the macro and micro perspective. It also provides examples from selected post-communist countries now in the EU, including the Czech Republic, Poland and Hungary. Concrete recommendations for economic policy round out the coverage.

Derivatives stand at the forefront of financial innovation, continually evolving to accommodate new asset classes and risk categories. In the past decade, the growing popularity of cryptoassets and ESG investments has sparked the development of a variety of innovative investment strategies and risk management tools, including crypto and ESG derivatives and related structured products. This new edition has similarly evolved. Using illustrative examples, it provides a comprehensive analysis of the key tax issues associated with derivatives and cryptoassets in domestic and cross-border transactions and presents approaches that tax legislators could adopt to solve them. The new edition also comments on recent trends in global tax policy, such as the OECD Base Erosion and Profit Shifting (BEPS) 1.0 and 2.0 projects. Throughout the book, specific references are made to UK, German, and Swiss tax law. The updated edition addresses the following topics: economic and financial properties of derivatives and cryptoassets; definition of derivatives for tax purposes and its application to crypto derivatives and ESG derivatives, among others; accounting treatment of derivatives and cryptoassets under IFRS, UK, German and US GAAP; current tax legislation and policy alternatives to the taxation of derivatives and cryptoassets; characterisation of derivatives gains and losses as income or capital, and equity or debt; accounting and taxation treatment of hedging transactions involving derivatives or cryptoassets; accounting and taxation rules applying to structured products and hybrid instruments, including crypto and ESG-linked structured products; withholding taxes on derivatives and the concept of beneficial ownership in domestic and cross-border transactions; and anti-avoidance legislation applying to derivatives and cryptoassets, including the domestic law implementation of BEPS Action 2, the EU Anti-Tax Avoidance Directives (ATAD I and II), the tax transparency rules for cryptoassets (DAC8) and Pillar Two. This comprehensive book analyses recent developments in three intertwined areas of expertise: financial products, accounting and tax law. It will be a valuable resource to tax professionals in their daily practice of advising companies, banks and investment funds. It will also be of interest to government officials and researchers engaged in the taxation of derivatives, cryptoassets, and ESG investment products.

The COVID-19 crisis has weakened an already fragile economy. South Africa’s growth underperformed during the past decade: GDP per capita was already lower in 2019 than in 2008. Unemployment remains high, at around 35%, and youth unemployment even exceeds 50%. In the meantime, spending pressures are mounting to close the financing gap in health, infrastructure and higher education.

Corporate Tax Statistics is a flagship OECD publication on corporate income tax, bringing together a range of information on corporate taxation, MNE activity, and base erosion and profit shifting (BEPS) practices. This second edition of Corporate Tax Statistics includes, for the first time, anonymised and aggregated Country-by-Country reporting data.

The topics of double non-taxation and hybrid entities have acquired particular importance in a context where transformations in the tax world have led to international commitments materialised in the OECD Base Erosion and Profit Shifting (BEPS) project. In what is the first systematic in-depth analysis of the OECD BEPS Action Plan 2 and hybrid entities, this timely book provides a critical review of the approach adopted by the OECD and proposes a deeply informed alternative method to deal with the problem of hybrid entity mismatches. The author analyses the interaction between the double non-taxation outcome and the use of hybrid entities in an approach not strictly linked to any specific tax jurisdiction. To this end, the analysis includes case studies and examples from a range of jurisdictions emphasising the international tax context, also including the application of tax treaties. Among the seminal matters covered in this edition are the following: foundations of the concepts of double non-taxation and hybrid entities; extensive analysis based on the rules of characterisation of foreign entities for tax purposes in the United States, Spain, Denmark, and Germany, as well as on the Poland/United States and Canada/United States tax treaties; in-depth analysis of the implications of Article 1(2) OECD Model Tax Convention and Article 3(1) Multilateral Instrument (MLI), especially considering the position of developing (source) countries; detailed analysis of the OECD BEPS Action 2 and its recommendations (linking rules), including its implementation in the EU Anti-Tax Avoidance Directive (ATAD); and elaborated alternative method to deal with hybrid entity mismatches (reactive coordination rule), which is informed by the tax policy aims of simplicity, coherence, and administrability. Detailed comparisons between the author’s proposal and other existing rules elucidate common points and deviations. If merely for its unparalleled clarification of the issues, this book will prove of immeasurable value to practitioners, tax authorities, policymakers and academics concerned with international tax law. Beyond that, as an authoritative guide that promises to reorient the discussion to what really matters in the debate regarding hybrid entity mismatches, this analysis elaborates solutions applicable to a generality of cases worldwide and, therefore, hugely promotes the urgent quest for alternative views.

Following the successful of previous conference, 3rd International Conference on Administrative Science, Policy, and Governance Studies (ICAS-PGS) in strategic alliance with 4th International Conference of Business Administration and Policy (ICBAP) 2019 will be held on October 30-31, 2019 in Universitas Indonesia, Depok, West Java, Indonesia. This year’s conference theme is “Strengthening Strategic Administrative Reform Policy to Promote Competitiveness and Innovation in Industrial Revolution 4.0: The Opportunities and Challenges.” This conference is hosted by Faculty of Administrative Science Universitas Indonesia (FIA UI). The conference covers debates over problematic situation, theoretical frameworks, as well as prescribed policies the way that governments, businesses, and civil societies essentially need to outline strategies to realize reform commitment and achieve change efficacy for purposes of harnessing innovation while considering the opportunities and challenges as well as maintaining sustainability, engaging in a more dynamic predicament such as regulatory frameworks that affect relations of multiple governance actors in today’s dynamic towards Industrial Revolution 4.0. The main objective of this conference is to discuss and debate the recent trends in administrative science on a range of issues such as public, business, and fiscal and the interconnectedness of all in Industrial Revolution 4.0. This conference is aimed to bring researchers, academicians, scientists, policymakers, professional managers, students, and other related stakeholders; together to participate and present their latest research findings, developments, and practical solutions related to the various aspects of administrative challenges in public and private sector. The general theme of 3rd ICAS-PGS and 4th ICBAP 2019 is “Strengthening Strategic Administrative Reform Policy to Promote Competitiveness and Innovation in Industrial Revolution 4.0: The Opportunities and Challenges.” The conferences consist of three streams representing differences of focus and scopes of research interests within the discipline of public, business, and fiscal administration and policy. We convey our gratitude to our esteemed Committee, Speakers and Participants, for giving their best to the success of the conference

In July 2020, the Investment Committee recommended to Council to invite Uruguay to become the 50th adherent to the OECD Declaration on International Investment and Multinational Enterprises. This OECD Investment Policy Review of Uruguay documents the progress made in recent years to align investment policies with the national development strategy in pursuit of the Sustainable Development Goals (SDGs).