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 31 October 2014 on Action 7 of the BEPS Action Plan.
CFE Opinion Statement FC 15/2014 concerns the possibility of developing a multilateral legal instrument to modify bilateral tax treaties, as proposed by the OECD on 16 September 2014 as part of the OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS). The Opinion Statement was prepared by the BEPS working group of the CFE Fiscal Committee and submitted to the OECD on 19 December 2014.
Opinion Statement ECJ-TF 4/2014 concerns the requirements to form "fiscal unity", commentining on the judgment of the European Court of Justice of 12 June 2014 on joined cases C-39, 40 and 41/13, SCA Group Holding B.V. et al. It has been prepared by the CFE´s ECJ Task Force.
Opinion Statement ECJ-TF 3/2014 concerns the taxation of unrealized gains upon a reorganisation within the EU, commenting on the judgment of the European Court of Justice of 23 January 2014 in the case C-164/12, DMC. The statement has been prepared by the CFE´s ECJ Task Force.
This is an opinion statement on improving the framework for voluntary disclosure, in response to the OECD public consultation. This opinion statement was prepared jointly by the Fiscal Committee and Professional Affairs Committee of the CFE.
This Opinion Statement was prepared jointly by the Fiscal Committee and Professional Affairs Committee of the CFE and sent to the European Commission, the European Parliament and the EU Council on the occasion of the European elections in May 2014.
Both CFE Opinion Statements refer to OECD BEPS Action 2: neutralise the effects of hybrid mismatch arrangements. The Statement FC 9/2014 was submitted in May 2014 to the OECD as a response to the discussion draft of 19 March 2014. Statement FC 4/2015 was submitted in February 2015 and comments on the OECD follow-up report of 16 September 2014.