Originally a criteria set out in the harmful tax framework from 1998, it had not been applied to date. The Inclusive Framework on BEPS has decided to resume the application of the substantial activities requirement for no or only nominal tax jurisdictions.
The results are a consolidated update of the regimes reported in Harmful Tax Practices – 2017 Progress Report on Preferential Regimes.Ĭountries with harmfull tax practices – preferential tax regimes – are defined based on the following factors: The data below presents the conclusions of the work on regime reviews. On 13 November 2018, the Inclusive Framework on BEPS approved updates to the results of reviews of preferential tax regimes conducted in connection with BEPS Action 5. Intangibles - Goodwill Know-how Patents.
UN Practical Manual on Transfer Pricing 2021.