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BEPS Action 12

Require taxpayers to disclose their aggressive tax planning arrangements

Description of this action in OECD's Action Plan (July 2013)

Develop recommendations regarding the design of mandatory disclosure rules for aggressive or abusive transactions, arrangements, or structures, taking into consideration the administrative costs for tax administrations and businesses and drawing on experiences of the increasing number of countries that have such rules. The work will use a modular design allowing for maximum consistency but allowing for country specific needs and risks. One focus will be international tax schemes, where the work will explore using a wide definition of “tax benefit” in order to capture such transactions. The work will be coordinated with the work on co-operative compliance. It will also involve designing and putting in place enhanced models of information sharing for international tax schemes between tax administrations.

Expected output and deadline for this action in OECD's Action Plan (July 2013)

Expected output : Recommendations regarding the design of domestic rules
Deadline: September 2015

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