Opinion Statements

CFE/AOTCA Opinion Statement FC 10/2015 on artificial avoidance of PE status (BEPS Action 7), revised Discussion Draft

This Opinion Statement comments on the revised OECD Discussion Draft on preventing the articificial avoidance of Permanent Establishment status. It has been drafted by the CFE Fiscal Committee and AOTCA and submitted to the OECD in June 2015, following up on the CFE/AOTCA Opinion Statement FC 1/2015.

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CFE/AOTCA Opinion Statement FC 11/2015 on preventing tax treaty abuse (BEPS Action 6), revised Discussion Draft

This Opinion Statement responds to the revised OECD Discussion Draft on preventing tax treaty abuse (BEPS Action 6). It is a follow-up to the CFE Opinion Statement FC 5/2014 and the CFE/AOTCA Opinion Statement FC 2/2015. It has been drafted by the CFE Fiscal Committee and AOTCA and submitted to the OECD in June 2015.

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CFE Opinion Statement FC 9/2015 on mandatory exchange of information on tax rulings

This Opinion Statement comments on the European Commission´s Directive proposal COM(2015)135 of 18 March 2015 on introducing mandatory exchange of information on cross-border advance tax rulings and advance pricing agreements. It has been drafted by the CFE Fiscal Committee.

An Opinion Release was issued on 13 June 2016, reflecting the developments since June 2015.

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CFE/AOTCA Opinion Statement FC 8/2015 on strengthening CFC rules (BEPS Action 3)

 

This joint Opinion Statement of CFE and AOTCA (Asia-Oceania Tax Consultants´ Associations) responds to the OECD public consultation on strengthening controlled foreign company (CFC) rules (BEPS Action 3). It has been prepared by the CFE Fiscal Committee together with AOTCA and submitted to OECD on 1 May 2015.

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CFE/AOTCA Opinion Statement FC 7/2015 and PAC 1/2015 on mandatory disclosure rules (BEPS Action 12)

This joint Opinion Statement of CFE and AOTCA (Asia-Oceania Tax Consultants´ Associations) responds to the OECD public consultation on mandatory disclosure rules for tax planning arrangements (BEPS Action 12). It has been prepared by the CFE Professional Affairs Committee and Fiscal Committee together with AOTCA and submitted to OECD on 30 April 2015.

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CFE/AOTCA Opinion Statement FC 3/2015 on making dispute resolution mechanisms more effective (BEPS Action 14)

This Opinion Statement has been prepared by the CFE Fiscal Committee and AOTCA (Asia-Oceania Tax Consultants´ Association) and sent to the OECD in January 2015. It comments on the OECD discussion draft of 18 December 2014 on Action 14 of the BEPS Action Plan.

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CFE/AOTCA Opinion Statement FC 2/2015 on tax treaty abuse (BEPS Action 6)

This Opinion Statement has been prepared by the CFE Fiscal Committee, agreed with the AOTCA (Asia-Oceania Tax Consultants´ Association) and sent to the OECD in January 2015. It comments on the OECD discussion draft of 21 November 2014 on Action 6 of the BEPS Action Plan.

It follows up on CFE Opinion Statement FC 5/2014 of April 2014.

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