As the United Arab Emirates, Qatar, Bahrain and Oman are also members of the BEPS
IF, the expectation is that these countries will introduce specific legislation to implement the OECD recommendations on transfer pricing and CbC reporting under Action 13 in due course.
Given the sweeping changes contemplated by the two pillars, as further delineated in the Consultation Document, it is unfortunate that the OECD is under political pressure to have its Inclusive Framework on BEPS
(the Inclusive Framework) agree on a solution by May of this year, followed by a report to the G20 Finance Ministers in June, and a final recommendation to be publicly delivered in 2020.
Pakistan is also a part of the Multilateral Convention to Implement Tax Treaty related matters to avoid BEPS
The OECD describes BEPS
as "tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity."
The main factor for the changes and alteration to international taxation, that greatly impacted aviation finance and leasing, is the OECD's Base Erosion and Profit Shifting (BEPS
) Action Plan and its heightened focus on double tax treaties.
The Convention is based on the OECD Model Convention for the Avoidance of Double Taxation on Income and on Capital and incorporates all the minimum standards of the Base Erosion Profit Shifting (BEPS
) project, as issued by the OECD/G20.
♦ Bahrain is to enter the Base erosion and profit shifting (BEPS
) Inclusive Framework - an international framework to combat tax avoidance by multinational enterprises.
The Central Board of Direct Taxes (CBDT) has proposed changes in the application process for obtaining advance ruling to bring it in line with Base Erosion and Profit Shifting (BEPS
) Action 5 objectives, which mandate spontaneous exchange of information on ruling with countries of immediate as well as ultimate parents of taxpayers.
issued the OECD BEPS
Action Plan in 2014 and amended the OECD Transfer
Al Khoori commented on the UAE's joining of the Action Plan on Base Erosion and Profit Shifting (BEPS
), noting that the UAE has notified the EU of its timeline for implementing the Plan's minimum requirements in coordination with experts from the organisation for Economic Cooperation and Development (OECD).