The OECD has just provided an update on the CBCR and "non-cooperative jurisdictions" work via a webcast. Pascal Saint-Amans and Achim Pross set out the latest thoughts. Here are the highlights.
The OECD has issued new, updated guidance on the implementation of CBCR. It can be found here.
There are four key elements, as shown on the slide. Achim talked about the first and last.
The first concerns the "parent surrogate filing" concession, which is a recognition of legislative constraints in some jurisdictions. It assists where groups are parented in a jurisdictions that adopts CBCR later than where the operating subsidiaries are located.
The last item sets out the the impact of currency fluctuations should not be a short-term issue. It says that if the €750 million limit was applied correctly at inception, there is no need to adjust for subsequent fluctuations in exchange rates, until review in 2020.
Non-cooperative jurisdictions
The Committee on Fiscal Affairs met on the criteria for identifying non-cooperative jurisdictions, and this will be presented by the OECD to G20. The proposal sets out three criteria for a "cooperative" jurisdiction, and by definition a country that does not meet at least two of these is deemed "non-cooperative".
The OECD will propose to the G20 that these criteria are adopted now, but that a list of non-cooperative jurisdictions is not generated until July 2017, to give countries the opportunity to meet these criteria before July 2017, and so not be listed.
I will be interesting to see how the G20 responds.
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