Oecd tax intermediaries study working paper 6

While the OECD BEPS project has produced a good framework for international corporate tax reform, the EU needs to tailor these to fit the Single Market so as to allow all EU countries to protect their tax bases. The Commission's approach has been to enshrine key BEPS measures into binding EU law, so that they are swiftly and smoothly implemented across the EU, leaving no room for different interpretations of these standards. The EU has sought to lead by example, using the BEPS standards as the basis on which to create a solid, legal framework for Member States.

UNCONTROLLED TRANSACTION  -- Transaction between independent and unrelated enterprises.
UNDER-CAPITALISATION  -- See: Thin capitalisation
UNDERLYING TAX  -- Tax which is charged on corporate income out of which dividends are paid, but which does not appear as a direct deduction or withholding from the dividend itself.
UNDERLYING TAX CREDIT  -- See: Credit, underlying tax
UNDISTRIBUTED PROFITS TAX  -- Annual tax imposed, in addition to the normal corporate income tax, on the undistributed portion of the profits or surplus of a corporation.
UNDUE HARDSHIP  -- A substantial financial loss that would result to a taxpayer from making payment on the due date of the amount of taxes with respect to which the extension is desired. Undue hardship is a condition precedent to the granting of an extension of time to make a tax payment.
UNEARNED INCOME  -- Term used to describe investment income such as dividends, interest and royalties.
UNILATERAL RELIEF  -- Granting of relief from the effects of international double taxation on the basis of domestic legislation rather than the provisions of a tax treaty.
UNIMPROVED PROPERTY  -- Land that has received no development, construction, or site preparation (. raw land).
UNITARY TAX SYSTEM  -- Under a unitary tax system, the profits of the various branches of an enterprise or the various corporations of a group are calculated as if the entire group is a unity. A formula is used to apportion the net income of the whole group to the various parts of the group. Usually a combination of property, payroll, turnover, capital invested, manufacturing costs, etc. are formula factors.
UNLIMITED LIABILITY  -- Liability of an investor which extends to the full extent of his personal assets, as in the case of a sole proprietor or general partner.
UPSTREAM DIVIDEND  -- Dividends flowing from a subsidiary company to its parent company.
USEFUL LIFE  -- Period during which it is estimated that a depreciable asset will provide useful service to the business in which it is used.
USE TAX  -- Tax on goods which are used within the taxing jurisdiction although the goods were purchased in another jurisdiction


New applicants must take and pass the examination within one year prior to applying to become an MPF intermediary.

Subsidiary intermediaries who have not registered within three years immediately before the date of application need to take and pass the examination again to re-register.

Subsidiary intermediaries who have failed to complete continuing training and had their registration revoked will need to take and pass the examination again to re-register.

The Mandatory Provident Fund Schemes Examination (conducted by the Vocational Training Council) and the MPF Intermediaries Examination  (conducted by the Hong Kong Securities and Investment Institute) are the qualifying examinations specified by MPFA as meeting the examination requirements to be an MPF intermediary.

The Juncker Commission has made great strides in boosting tax transparency and tackling tax evasion and avoidance. New EU rules to block artificial tax arrangements , as well as new transparency requirements for financial accounts , tax rulings and multinationals' activities have already been agreed and are progressively entering into force. Proposals for stronger Anti-Money Laundering legislation, public Country-by-Country reporting requirements and tougher good governance rules for EU funds are currently being negotiated. In addition, a new EU list of non-cooperative tax jurisdictions should be ready before the end of the year.

The Common Reporting Standard (CRS) , developed in response to the G20 request and approved by the OECD Council on 15 July 2014, calls on jurisdictions to obtain information from their financial institutions and automatically exchange that information with other jurisdictions on an annual basis. It sets out the financial account information to be exchanged, the financial institutions required to report, the different types of accounts and taxpayers covered, as well as common due diligence procedures to be followed by financial institutions.

Oecd tax intermediaries study working paper 6

oecd tax intermediaries study working paper 6

The Juncker Commission has made great strides in boosting tax transparency and tackling tax evasion and avoidance. New EU rules to block artificial tax arrangements , as well as new transparency requirements for financial accounts , tax rulings and multinationals' activities have already been agreed and are progressively entering into force. Proposals for stronger Anti-Money Laundering legislation, public Country-by-Country reporting requirements and tougher good governance rules for EU funds are currently being negotiated. In addition, a new EU list of non-cooperative tax jurisdictions should be ready before the end of the year.

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