This publication includes three recent reports of the Committee on Fiscal Affairs that resulted in changes to the OECD Model Tax Convention on Income and Capital (those changes were included in the update adopted by the Council of the OECD on 28 January 2003): "Restricting the Entitlement to Treaty Benefits", "Treaty Characterisation Issues Arising From E-Commerce: Report Adopted by the Committee on Fiscal Affairs", and "Issues Arising Under Article 5 (Permanent Establishment) of the Model Tax Convention".

This report reflects on the implications of the evolving international tax policy landscape for international tax co-operation, and provides an update on the 2022 Report “Tax Co-operation for the 21st Century” and the 2023 Progress Report. The principles of tax co-operation set out in those reports have become even more important in light of the implementation of the Global Minimum Tax, which took effect from the beginning of this year. This report sets out the advances being made in implementing the vision for co-operation amongst tax administrations with a specific focus on the Global Minimum Tax. It also sets out areas of tax co-operation beyond the corporate tax system looking at recent developments in the exchange of information between tax administration as well as other transparency initiatives with respect to taxation of individuals. Finally, it addresses the implications of these developments in the international tax system for developing countries with respect to both direct and indirect taxes as well as the digitalisation of tax administration. This report was prepared by the OECD to inform the discussions at the May 2024 meeting of G7 Finance Ministers and Central Bank Governors, at the request of the G7 Italian Presidency.

This report provides a comprehensive analysis of the Israeli system of local government finance, with a focus on the role of the Israeli property tax, known as the Arnona. Local governments are financed through a combination of revenue, primarily from central government grants and from the Arnona, which is levied on residential and non-residential land and buildings but is based on their physical size rather than their value. The first chapter provides a description of the Israeli system of local government finance and compares it to local government finance in OECD countries. Using standard criteria for the evaluation of taxes, the second chapter assess the strengths and shortcoming of the Arnona and the intergovernmental grant system. Attention is paid to fiscal disparities among municipalities and to the ability of the current system to provide all Israelis with adequate and equitable access to economic and social services and infrastructure. The final chapter presents a set of 13 policy recommendations divided between proposals for improving the existing Arnona system and a longer-run blueprint for a more substantial reform of the system of local government finance in Israel based on the establishment of a value-based system of local property taxation.

Taxation is at the core of countries' sovereignty, but in recent years, multinational companies have avoided taxation in their home countries by pushing activities abroad to low or no tax jurisdictions.  The G20 asked OECD to address this growing problem by creating this action plan to address base erosion and profit shifting. This plan identifies a series of domestic and international actions to address the problem and sets timelines for the implementation.

Base erosion constitutes a serious risk to tax revenues, tax sovereignty and tax fairness for many countries. While there are many ways in which domestic tax bases can be eroded, a significant source of base erosion is profit shifting. This report presents the studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters and identifies the key principles that underlie the taxation of cross-border activities, as well as the BEPS opportunities these principles may create. The report concludes that current rules provide opportunities to associate more profits with legal constructs and intangible rights and obligations, and to legally shift risk intra-group, with the result of reducing the share of profits associated with substantive operations. The report recommends the development of an action plan to address BEPS issues in a comprehensive manner.

Kazakhstan has recorded impressive economic growth rates since its independence, driven mainly by export of commodities and high rate of energy use. These rates are not sustainable and are generating significant air pollution, in particular from industrial stationary sources. This is putting at risk the country’s development ambitions to become one of the top global economies by 2050 and converge towards OECD living standards. Building on OECD previous analysis, this publication shows that Kazakhstan’s environmental payments (environmentally related taxes, non-compliance penalties and compensation for damage regulation) for industrial air pollutants, as currently applied, impede energy efficiency and pollution abatement with heavy-handed non-compliance responses and focus on rising revenues. They also add to the cost of doing businesses in the country with limited environmental benefit. In the spirit of the Polluter-Pays Principle, much more reforms of regulation of environmental payments are needed. This report provides guidelines for reform drawing from air pollution regulations in OECD member countries and the results of the analysis of the system in Kazakhstan carried out by the OECD in close co-operation with the Government of Kazakhstan.

The financial and economic crisis had a devastating impact on bank profits, with loss-making banks reporting global commercial losses of around USD 400 billion in 2008.  This comprehensive report sets the market context for bank losses and provides an overview of the tax treatment of such losses in 17 OECD countries; describes the tax risks that arise in relation to bank losses from the perspective of both banks and revenue bodies; outlines the incentives that give rise to those risks; and describes the tools revenue bodies have to manage these potential compliance risks. It concludes with recommendations for revenue bodies and for banks on how risks involving bank losses can best be managed and reduced.

The spread of the digital economy poses challenges for international taxation. This report sets out an analysis of these tax challenges. It notes that because the digital economy is increasingly becoming the economy itself, it would not be feasible to ring-fence the digital economy from the rest of the economy for tax purposes. The report notes, however, that certain business models and key features of the digital economy may exacerbate BEPS risks. These BEPS risks will be addressed by the work on the other Actions in the BEPS Action Plan, which will take the relevant features of the digital economy into account. The report also analyses a number of broader tax challenges raised by the digital economy, and discusses potential options to address them, noting the need for further work during 2015 to evaluate these broader challenges and potential options.

The spread of the digital economy poses challenges for international taxation. This report sets out an analysis of these tax challenges.  It notes that because the digital economy is increasingly becoming the economy itself, it would not be feasible to ring-fence the digital economy from the rest of the economy for tax purposes. The report notes, however, that certain business models and key features of the digital economy may exacerbate BEPS risks, and shows the expected impact of measures developed across the BEPS Project on these risks.  The report also describes rules and implementation mechanisms to enable efficient collection of value-added tax (VAT) in the country of the consumer in cross-border business-to-consumer transactions, which will help level the playing field between foreign and domestic suppliers. The report also discusses and analyses options to deal with the broader tax challenges raised by the digital economy, noting the need for monitoring developments in the digital economy over time.

Populations in OECD and emerging economies are ageing rapidly, which will have significant macroeconomic impacts, including on public expenditures and tax revenues. The rules and practices that govern fiscal relations among different levels of government, such as their responsibilities for taxation, spending and debt management, have a bearing on economic efficiency and ultimately growth. The consequences of population ageing at subnational government levels are especially intense. Many local governments are vulnerable to the ageing of their populations from a fiscal perspective. The economic and fiscal challenges of an ageing population go beyond intergovernmental boundaries, and they require complex intergovernmental policy responses. This volume brings together cross-country studies of fiscal policy, demographics and spatial productivity, as well as country studies of Brazil, Canada, China and Germany.

This Agreement contains two models for bilateral agreements drawn up in the light of the commitments undertaken by the OECD and the committed jurisdictions. The Working Group was chaired by Malta and the Netherlands and marks the first results of the OECD's collaboration with the jurisdictions that have committed to improve transparency and establish effective exchange of information in tax matters.

The report contains revisions to the OECD Transfer Pricing Guidelines to align transfer pricing outcomes with value creation. The revised guidance focuses on the following key areas: transfer pricing issues relating to transactions involving intangibles; contractual arrangements, including the contractual allocation of risks and corresponding profits, which are not supported by the activities actually carried out; the level of return to funding provided by a capital-rich MNE group member, where that return does not correspond to the level of activity undertaken by the funding company; and other high-risk areas. The report also sets out follow-up work to be carried out on the transactional profit split method which will lead to detailed guidance on the ways in which this method can appropriately be applied to further align transfer pricing outcomes with value creation.

Illicit financial flows (IFFs) such as tax evasion are a major policy challenge for developing and emerging economies, in particular as the COVID-19 pandemic has drained domestic resources. This report presents results from a joint project between the OECD and the National Treasury of South Africa, which assesses tax compliance and IFFs in South Africa. The report provides an overview of macroeconomic, tax and fiscal developments in South Africa since the global financial crisis. It discusses the concepts of IFFs, how they relate to the South African context and provides an overview of South Africa’s participation in multilateral initiatives to combat tax evasion. It also provides a quantitative analysis of tax compliance and IFFs over time amid a variety of tax transparency initiatives implemented in South Africa. Finally, the report examines the effectiveness of tax transparency initiatives such as voluntary disclosure programmes, and looks into income and wealth characteristics of applicants to these programmes.

Currently, there is a lack of consensus amongst OECD Member countries as to how profits should be attributed to a permanent establishment (PE). As a first step in remedying this situation a working hypothesis has been developed as to the preferred approach for attributing profits to the PE. The basis for the working hypothesis is to examine how far the approach of treating the PE as a hypothetical distinct and separate enterprise can be taken and how the guidance in the OECD Transfer Pricing Guidelines could be applied, by analogy, to attribute profits to a PE. This discussion draft contains the results of testing the working hypothesis in general (Part I) and to PEs of banks (Part II). Public comments are invited in order to assist in the development of an OECD consensus on the attribution of profits to a PE.