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OECD Releases Seychelles TP Guidance

by Mike Godfrey, Lowtax.net, Washington
28 September, 2018

This month the OECD released a guide on the transfer pricing policies in place in Seychelles.

The guidance is in the form of a Transfer Pricing Country Profile, which the OECD prepared based on answers received from the domestic tax agency, as part of its work to support taxpayers to come to terms with transfer pricing changes that have been made, or are being proposed, in response to its recommendations on tackling base erosion and profit shifting.

BEPS refers to tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations. The BEPS package provides 15 Actions to equip governments with the domestic and international instruments needed to tackle BEPS, by ensuring that profits are taxed where economic activities generating the profits are performed and where value is created.

Having released these reports, the OECD launched the BEPS Inclusive Framework, of which Seychelles is a member, within which over 100 countries and jurisdictions are collaborating to implement the BEPS measures and tackle BEPS.

As a member of the Inclusive Framework, Seychelles has agreed to remove any "harmful" tax provisions from in its domestic tax regime, amend its tax treaty rules to prevent treaty abuse, implement country-by-country reporting rules and exchange the reports it receives from multinationals with other countries, and work with other BEPS Inclusive Framework members to improve cross-border tax dispute resolution mechanisms.

The new guidance on Seychelles' transfer pricing regime is in the form of answers to frequently asked questions, covering 29 areas of the territory's regime. The tax agency in its answers has provided citations to the relevant legislation with hyperlinks.

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