Overview of Asia Oceana Tax Consultants Association
International Tax Conference 2014
Asia Oceana Tax Consultants Association’s (AOTCA) International Tax Conference 2014 was successfully held in Taipei, Taiwan between Oct 22 and Oct 25. More than 400 delegates from 12 countries participated in the conference and 19 scholars had presentation on international tax issues. On the behalf of TOD TAX LLC, one tax consultant of the firm had participated in the conference.
Main agendas of AOTCA International Tax Conference 2014
The most important topic of International Tax Conference 2014 was Base Erosion and Profit Shifting (BEPS) and OECD’s 15 Action Plans to avoid BEPS. In last September, OECD has published 7 Action Plans and the rest are scheduled to be completed in 2015.
Principles of 15 Action Plans against BEPS
Principle | Explanation | Action number |
Coherent | International coherence in company income tax to prevent double (non) taxation | Action – 2, 3, 4, 5 |
Substance | Aligning tax right in the area of transfer pricing, arm’s length principle | Action – 6, 7, 8, 9 |
Transperancy | Improved data collection and analysis regarding impact of BEPS | Action – 11, 12, 13, 14 |
Main ideas of BEPS Action Plans issued by OECD:
Expand definition of permanent establishment
Strengthen Controlled Foreign Corporation rules
Strengthen withholding taxes
Strengthen transfer pricing
New VAT rules
Domestic laws to address arrangements that result in double non-taxation or long term tax deferral
Changes to OECD Model Tax Treaty
Consideration of revisions or additions to the existing framework for analyzing whether regimes are harmful
Anti-avoidance rules built into treaties
Special rules for intangibles
Use of fixed appointment methods: Country by Country Report Template
Amend tax treaties across world all at once
Avoid inconsistent tax treaty provisions
During the conference, representatives of various countries demonstrated their perspectives on OECD Action Plan and shared practices currently employed to counter with BEPS issues in their respective countries as well. Therefore, the conference was very fruitful as it enables defining conjoint standing of countries of the Asia Oceania region toward Action Plans of OECD.
Prepared by: Ariunaa.J
Sources:
OECD (2013), ‘Action Plan on Base Erosion and Profit Shifting’. OECD Publishing. http://dx.doi.org/10.1787/9789264202719-en
AOTCA (2014), ‘BEPS, Case Study and Korean Aspect’. Proceedings of the 12th AOTCA International Tax Conference. Ko, J. (ed). KACPTA. 25-26 Oct, 2014.
AOTCA (2014), ‘Practitioner Forum on BEPS Issues Focus – Hong Kong’. Proceedings of the 12th AOTCA International Tax Conference. Thomas, L. (ed). AOTCA. 25-26 Oct, 2014.
AOTCA (2014), ‘U.S. View on BEPS’. Proceedings of the 12th AOTCA International Tax Conference. Thomas, L. (ed). Cadesky and Associates. 25-26 Oct, 2014.