OECD Project Research Articles

New paradigm in tax management in the footprints of industry 4.0: tax administration 3.0

Purpose- In the 2020’s the tax management is following the footprints of Industry 4.0, tax Office processes which were originally paper-based and partly manual have been digitalised globally, also allowing greater sharing of data within the administration and within government, the incorporation of third party data and the use of enhanced analytical tools. We proposed to start the assessment of the level of the maturity of Turkish tax office’s e- transformation project under the criteria of OECD and compare with similar countries with more advanced and established systems. Methodology- Based on the systematic of OECD Digital Transformation Project Tax Office 3.0 the study planned to cover the six building blocks (tax identity, touchpoints, data management, tax rule and applications, analytic capacity and asssesment and governance frameworks and related 13 indicative attributes and to propose an approach to apply to the Turkish tax Office. Findings- Change in management of tax offices is urgently needed and the sytem is increasingly difficult to manage since the current position is inherently unstable. Some of the 48 countries studied by the OECD Project that have a road map to digital transformations appear to have more mature (established) digitalised tax systems than Türkiye, but we observed that our system which has only started in 2010’s has progressed rapidly especially during the last five years. Turkish Ministry of Treasury and Finance, which has taken substantial steps in the tax system, is now aiming to develop the process that has started with the e-document by expanding the comprehenesiveness of the industries as well as establishing new vanguard projects as the “Turkey Digital Tax Office”. Conclusion- Our findings provide evidence that the tax office can perform better with taxpayer and accountant’s voluntary compliance to system. The study concluded that digital transformation requires integrated approaches and a new approach to co- develop the different systems of government with the tax Office. Turkish Tax Office has to improve the core capabilities necessary to facilitate future tax administration, and fit them together taking into account the mutual costs of change. It is recommended to the Turkish Ministry of Treasury and Finance in order to improve the maturity of the Turkish digital transformation, to develop new strategies to harmonise the needs and interests of government and private sector actors within an integrated digitalized system rather than expanding and diversifying the existing system. Keywords: Building blocks of digital transformation, tax offices, taxpayer compliance. JEL Codes: G28; G38, K34

Digital Taxes and the Reprogramming of the Web: The OECD Project and its Implications for our Information Networks

Digital Taxes and the Reprogramming of the Web: The OECD Project and its Implications for our Information Networks

Challenges in transfer pricing: A concept of safe harbours for financial transactions

Abstract The OECD project against BEPS has brought and initiated many changes – among others, in the OECD Transfer Pricing Guidelines. To react and respond to changes in the current business environment, a new chapter for transfer pricing in financial transactions has also been introduced (namely chapter X). This step can be considered beneficial. However, meeting all the requirements for setting a transfer price for financial transactions seems to remain a very demanding and expensive task. Furthermore, the OECD Transfer Pricing Guidelines have been of a general nature rather than providing responses to all potential problems and circumstances – they provide fundamental ideas and principles. Thus, the potential to apply a simplified procedure for setting a transfer price (even for financial transactions) can be viewed as desirable, both for taxpayers and tax authorities. The aim of the paper is linked to this idea – to present the results of a comparative study dealing with the rules for safe harbours for financial transactions (namely loans) as established worldwide, providing a summary of existing concepts and systematized criteria for a safe harbour to be considered.

Exploring the Origins of the Financial Crisis: A Worldwide Overview

* Paul Ramskogler is a money related master at the Austrian Central Bank OeNB. This article depends upon a more no fuss recorded report by Ramskogler, 2014. It means to make the rule fulfillments of the report more open without giving more point-by-point information and evaluation. The report was readied while the writer got support from the OECD Project on New Approaches to Economic Challenges (NAEC). The outcomes were introduced and examined at an OECD-NAEC intriguing course with regards to Paris on 22 September 2014. This work will be scattered under the commitment of the Secretary-General of the OECD. The suppositions granted and the debates set forth do not really mirror the forced assessment of the Member States. This report and any guide of this document will not affect the norm or command over a zone, the constraints of overall lines and the name of a locale, city, or district.

Outcome measurement in trauma surgery with a fracture database and clinical and patient-reported outcome measures (PROMs)

Abstract Objective Patient-Reported Outcome Measures (PROMs) gain growing attention. The Food and Drug Administration suggested in 2009 to have PROMs for every new treatment and technology. The use of PROMs was further promoted by the Patient Protection and Affordable Care Act of 2010 in the USA. Recommendations from other national and international organizations include the OECD's Project of Patient-Reported Indicator Surveys (PaRIS) and the International Consortium for Health Outcomes Measurement (ICHOM). Our development and initiation of a Fracture Database started early in 2018. We orientated our database on the role model of the Swedish Fracture Registry. Methods REDCap (Research Electronic Data Capture) is a web interface for a SQL (Structured Query Language)-Database. We used it to program the Fracture Registry. We collect data about demographics, diagnosis, treatment, adverse events, clinical outcomes, and PROMs. The PROMS are recorded with the Software 'Heartbeat ONE' vs. 6.15.4. Inclusion criteria are all patients with fractures of the upper and lower extremity, including the pelvis and multiple injuries, treated surgically. Excluded are all patients with fractures of the hand as monotrauma and non-surgical treatment. We established questionnaire sets for each anatomical region. Every hospitalized patient is screened for inclusion criteria to get the baseline PROMs. Follow-up PROMs are collected at 3-months and 12-months in our outpatient clinic. Results In five months of collecting PROMs, we have evaluated 599 patients, 521 fulfilling the inclusion criteria. 329 (63%) questionnaire sets were completed. The mean time for answering the questions was 11-20 minutes. The input rate of 63% for PROMs accounts for the start of the process, with 22 (4%) patients being dismissed before answering the questionnaires. 93 (18%) patients denied participation. 52 (10%) patients were not able to participate (dementia, delirium). Other causes for missing data were language barriers (n = 28; 5%), medical reasons like polytraumatized patients (n = 4; 0.8%), and deceased patients (n = 15; 2.9%). Conclusion Most Orthopaedic Trauma centers publish data about PROMs from surgically treated patients. Starting in the first quarter of 2021, we will include non-surgically treated patients. We have optimized the process of including patients. Our aim is a response rate of more than 80% within this year to get representing data.

International Transfer Pricing: MNE Dependency on Knowledge of External Tax Consultants

ABSTRACTThis paper explores the dependency of multinational enterprises (MNEs) on the international transfer pricing (ITP) knowledge offered by external tax consultants. Based on interviews with 13 ITP/tax executives working for large MNEs in the U.K., we find that the dependency on consultants varies significantly across specific ITP tasks. This dependency is not rooted in a lack of in-house technical ITP knowledge. Rather, consultants offer important industry and process knowledge, often at the individual tax inspector level, that MNEs need to successfully implement their ITP policy and to handle negotiations with tax authorities. The recent OECD project on Base Erosion and Profit Shifting (BEPS) is found to have a limited effect on MNE dependency on consultants, except for the documentation task. We conclude that the profile of consultants as knowledge experts depends on the specific ITP task they undertake.

Can Anyone Be Trusted to Enforce National Treatment Disciplines With Respect to Tax Measures?

Because the traditional non-discrimination article of tax treaties seem­ingly provides protection against only the most blatant discrimination against non-residents and non-nationals of a taxing State, governments may be emboldened to adopt “anti-abuse” rules that are in reality dis­guised trade barriers. On the other hand, trade disciplines in non-tax agreements may include protections against discriminatory taxes that non-specialist courts interpret in expansive ways, contrary to the wishes of tax authorities. An OECD project in the mid-2000s was an opportu­nity for governments to re-think the piecemeal nature of the traditional non-discrimination article in tax treaties and develop a coherent national treatment system that takes into account legitimate tax policy concerns. Instead, the project resulted in a mishmash of changes that largely blessed the various discriminatory practices that governments had adopted to that date. If tax authorities want to continue to play a leading role in developing international tax policy, they should consider whether a tax treaty approach that borrows concepts from non-tax agreements would better balance the interests of governments and tax­payers than the current version of Article 24 (and the Commentaries thereon).

Methodology of interdisciplinary research on the example of scientific research of the human genome

The problems of methodology of scientific research activity are actual to-day due to discoveries in Physics, Biology and Cosmology Due to widespread international cooperation and advances in the field of genomics (especially in sequence analysis), as well as major advances in computing technology, a «rough draft» of the genome was finished in 2000. This first available rough draft assembly of the genome was completed by the Genome Bioinformatics Group at the University of California. The OECD Project «Human Genome» is the first experience of application of methodology of scientific research activity based on mathematic modeling and cipher technology. The institutions, companies, and laboratories, engaged in OECD Human Genome Project, form a system based on laws and regulations, treaties and agreements, contracts and regulatory orders. This Model of methodological approach might have been used in other interdisciplinary scientific research activities. The study was carried out with the financial support of the Russian Foundation for Basic Research in the framework of research project No. 18-29-14025 on the topic: “Legal regulation of genomic research and the use of their results: comparative legal aspect of research».

ЯКІСТЬ ОСВІТИ УКРАЇНИ ЗА РЕЗУЛЬТАТАМИ PISA–2018 І ПРОЄКТ ОЕСР «МАЙБУТНЄ ОСВІТИ І КОМПЕТЕНТНОСТЕЙ 2030»

Since its inception in 2000, the international comparative survey of education qua­lity PISA has become a globally recognized powerful lever for improving national education systems, determining their state and development trends according to internationally agreed indicators based on measurements using internationally agreed tools (tests and questionnaires) and procedures for preparation, administration and evaluation of results. In 2015, the OECD launched the "Future of Education and Skills 2030" project, aimed at developing the foundations for an effective education system for the future, the first phase of which culminated in 2019 with the creation of the OECD Learning Compass 2030, a conceptual framework for future school curricula and studying in a learner context. At the second stage, it is planned to create the foundations of effective educating in the context of a teacher. These documents should play the role of the foundation for making the PISA program better by improving, first of all, the PISA subject frameworks in the main domains: reading, mathematics and natural sciences. For the effective improvement of Ukraine's education system, it is important not only to analyse its current state, in particular, its PISA-2018 results, but also to pursue a long-term educational policy aimed at developing an educational model that is based on national educational and cultural achievements and traditions, and is also consistent with the developments of the OECD project "The Future of Education and Skills 2030". The article analyzes the key ideas of the OECD Learning Compass 2030 and discusses some issues of their implementation in the educational practice of Ukraine.

Amendment of India Mauritius DTAA and its Impact on Foreign Investment in India

The objective of this paper is to the study the impact of the amendment of India Mauritius DTAA on foreign investment in India. It provides adetailed analysis of how Mauritius, a small island country became the most favourite route for foreign investor in India during the period 2000 to 2017. The paper identifies the reasons for emergence of Mauritius as the foremost exporter of foreign capital to India and in this context examines the role of the Agreement on Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes of Income and Capital Gains between India and Mauritius (DTAC). In 2016, DTAC was amended and with the implementation of General Anti Avoidance Rule (GARR) from 2017 by India and changes in international taxation zeitgeist due to OECD project on Base Erosion Profit Shifting (BEPS) the Mauritius route faced new challenges. The paper studies the influence of these changes on FPI and FDI investments flow from Mauritius to India.It finds that advantage of Mauritius in FDI and FPI flow has come down in 2018-19 and its share in foreign investment is likely to come down further with the amendment of the DTAC taking full effect from April 2019. However,amendment has given Mauritius a competitive advantage in channelizing debt investment to India as compared to its competitors like Singapore and the Netherlands and in future we may see higher debt investment from Mauritius.

Experimental study of smoke effects on energized electrical cabinets located nearby a lubricant oil pool fire

SummaryThis paper presents an experimental study of smoke exposure effects on potential malfunction of three electrical cabinets located nearby an oil pool fire. This study was performed as part of the PRISME‐2 international OECD project. Lubricant oil was used as fire source, and three real energized electrical cabinets were used as targets exposed to smoke in the adjacent room to the fire room. The main fire properties, as well as the fire consequences, such as gas temperatures and smoke concentrations in the rooms, and the cabinets are presented in detail. The heat release rate was thus assessed at around 500 kW for nearly all the fire duration, and maximum gas temperatures reached 300°C in the fire room, and 120°C in the adjacent room. Moreover, the maximum gas temperatures and soot mass concentrations inside the cabinets ranged from 90 to 120°C and from 0.3 to 1 g/m3, respectively. Nevertheless, continuous electrical monitoring of the three cabinets did not highlight malfunction. After the experiment, monitoring test of the cabinets was conducted to investigate the potential effects. The isolation resistance of electrical circuits on the most severe smoke exposed cabinet reduced during the monitoring test. It seemed the soot deposition have caused it.

The Contribution of Trans-Governmental Networks of Regulators: To International Regulatory Co-Operation

This study takes stock of the membership, governance structure, operational mode and regulatory power of trans-governmental networks of regulators (TGNs). It contributes to a greater OECD project aimed at building greater understanding of the benefits and pitfalls of various approaches to international regulatory co-operation (IRC) as identified in OECD (2013), International Regulatory Co-operation: Addressing Global Challenges.In order to fill the knowledge gap, this study provides a working definition of TGNs, maps existing cases, and analyses their key features. It relies on information gathered for this study on 144 TGNs. It analyses the substantive fields in which TGNs operate as well as differences in membership and other structural features. It discusses the range of regulatory activities in which TGNs engage and analyses the advantages and the disadvantages of TGNs as mechanisms for IRC, based on a review of the large and growing scholarly literature. It provides a new database on the topic, as well short case studies of three significant but structurally dissimilar TGNs: the Asian Harmonization Working Party (AHWP) on medical devices, the International Association of Insurance Supervisors (IAIS), and the International Council for Harmonisation of Technical Requirements for Pharmaceuticals for Human Use (ICH).

The Knowledge Triangle in the Healthcare Sector — The Case of Three Medical Faculties in Norway

The paper investigates the social role of education and the relevance of university programs to the real needs of society, which has gained especial political importance in recent years. Attention to this topic, in turn, has fueled interest in the concept of the «knowledge triangle», which implies a synergistic effect from the interplay of education, research, and innovation. Existing studies on the interaction of higher education institutions (HEIs) with society and policy in this field are primarily focused on the links between science and innovation and on the contributions of HEIs to economic development and growth. Many researchers focus on the interaction between universities and the industrial sector but ignore HEIs’ involvement in creating innovations in the public services sector. This is rather peculiar, considering that innovation in the public sector has received increased policy attention over the recent period, and is seen as essential for improving the efficiency and quality of public services and for addressing some of the major societal challenges, linked, for example, to an ageing population and maintaining the welfare state.This paper looks at the healthcare sector, where HEIs interact with private industry as well as public healthcare services. It builds upon a study from Norway carried out in 2015 in the framework of an OECD project, which mapped and analyzed knowledge triangle policies and practices at the national and institutional level. This study showed that interplay between education, research, and innovation is a key concern in the national policy for the development of the health sector, and that knowledge triangle interactions with both the private and public sector is a central aspect of the current practices at the medical departments at Norwegian HEIs. The linkages between the medical faculties and public healthcare services are especially interesting, as they provide patterns of interaction beyond those identified in the existing literature and because education plays a central role.

Measuring the Financial Literacy of the Adult Population: The Experience of Banca D’Italia

At the beginning of 2017, Banca d’Italia conducted a survey to investigate financial literacy and inclusion among Italian adults. The survey is part of an OECD project to create an internationally comparable dataset on this important topic. The questionnaire was developed by the OECD International Network on Financial Education (INFE). The Italian sample consists of about 2,500 persons interviewed using two different methods: 40 per cent of them had a face-to-face interview while the others used a tablet to record their responses. Our findings show the existence of a substantial financial literacy gap between Italy and the other G20 countries, which is most evident among less educated respondents, among the elderly and among women. Compared with other countries, Italians are more aware of their limits or at least more cautious when assessing their level of financial knowledge. We also discuss some critical aspects of the OECD’s methodology that should be addressed in order to improve the measurement of financial literacy and to increase cross-country comparability.

Assessment of androgen receptor agonistic/antagonistic effects on 25 chemicals in household applicants by OECD in vitro stably transfected transcriptional activation assays

The aim of this study is to assess the androgen receptor (AR) agonistic/antagonistic effects on various chemicals, which are used in household products including cleaning agents and wetted tissues by in vitro OECD test guideline No. 458 (using AR-EcoScreen™ cell line) and the me-too test method (using 22Rv1cell line), which was adopted as OECD project No. 4.99. All chemicals were not determined as AR agonists. However α-dodecyl-ω-hydroxypoly (oxyethylene) and 3-iodo-2-propynyl butylcarbamate have shown a weak AR antagonistic effects with IC50 values of 2.18 ± 0.12 and 4.26 ± 0.17 μg/ml via binding affinity to AR in only 22Rv1/mouse mammary tumor virus using AR transcriptional activation assay, because of their different cytotoxicity on each applied cell line. This report firstly provides information about agonistic/antagonistic effects against human AR of various chemicals including surfactants and biocides by OECD in vitro stably transfected transcriptional activation assays. However, further in vivo and human model studies are needed to confirm their adverse effects.

Instruments for Conservation and Sustainable Use of Water Resources in the Baikal Natural Area

The present paper contains the results of a review of economic instruments for water resources management in the Republic of Buryatia prepared under the OECD project “Improving the use of economic instruments for water management in the Republic of Buryatia (Lake Baikal basin)” and aimed at supporting the policy dialogue on water in Russia, in cooperation with the EU Water Initiative. Based on the analysis, some recommendations were developed for improving the use of instruments for water resources management in the Republic of Buryatia as a part of the Baikal Natural Area.

Analysis of PWR ex-vessel steam explosion for axial and side melt release

A steam explosion, in the frame of nuclear reactor safety, is a process resulting from the interaction between the core melt and water. Steam explosions are an important nuclear safety issue because they can potentially jeopardize the primary system and the containment integrity of the nuclear power plant. In the year 2007 the OECD project SERENA was launched, trying to resolve the open issues in steam explosion understanding and modelling, with the focus on reactor applications. To verify the progress made in the understanding and modelling of the fuel coolant interaction key phenomena for reactor applications a reactor exercise has been performed at the end of the project.In the paper the PWR ex-vessel steam explosion study, which was carried out with the MC3D code in conditions of the SERENA reactor exercise, is presented and discussed. The axial melt release case was simulated in 2-D and the side release case in 3-D. In reactor calculations the largest uncertainties in the prediction of the steam explosion strength may be expected due to the large uncertainties related to the jet breakup. Therefore the premixing simulations were performed with both available jet breakup models, i.e. a global and a local one, to get some insight in these uncertainties. For each premixing simulation an explosion simulation was performed, triggering the explosion around the time of the melt bottom contact. It turned out that despite the different jet breakup in both considered approaches, the calculated pressure loads are in the same range due to compensating effects. However, there were significant differences in the pressure loads between the axial and side release cases. With the side release the explosion occurs near the cavity wall and so the pressure loads on the wall are much higher. The 3-D modelling approach enables the study of realistic scenarios, thus for reliable reactor simulations it is important that the fuel coolant interaction codes have adequate 3-D modelling capabilities.

(De)politicizing good governance: the World Bank Institute, the OECD and the politics of governance indicators

Since the early 1990s there has been a surge in international efforts to calculate the comparative performance of states in terms of various characteristics of governance. In this article we show how numerical objectification of social phenomena can function to depoliticize potentially political issues. As a case of example we examine the evolving field of measuring good governance through analyzing the documentation of the World Bank Institutes established Worldwide Governance Indicators and its recent contender, the OECD project “Government at a Glance”, which argues to provide an alternative to the existing rankings. Although we observe certain methodological discontinuities in measurement practices of the OECD, these have hardly been serious enough to activate its potential in repoliticisizing the issue of “good governance”. Moreover, the work of OECD further strengthens and legitimates the epistemic expert authority of global index producers.

Transfer Pricing, Business Restructurings and Intangibles - Case Studies: UPS v. Commissioner; DSG Retail Ltd. v. HMRC

United Parcel Service of America, the largest motor carrier in the US, and DSG Retail the largest retailer of electrical goods in the UK, restructured operations and established captive insurance companies in offshore tax havens. In both instances, these restructurings removed sizeable amounts of income from the domestic tax base. The IRS and HMRC opened transfer pricing audits. The UPS case involved tax year 1984 and was settled in 2003; DSG Retail involved 1997 through 2005 and was settled in 2009. Both settlements came on the heels of government-favorable court decisions, and prior to the addition of Chapter IX to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (the Guidelines). The OECD added Chapter IX on Transfer Pricing Aspects of Business Restructurings, to the Guidelines on July 22, 2010. The core transfer pricing issue in a captive insurance case (in OECD terms) is the measure of compensation that should be returned to a domestic company by its captive on the transfer to it of (a) the business opportunity, or (b) the right to provide re-insurance on policies that underwrite risks of retail customers. Twenty days prior to announcing business restructuring additions to the Guidelines, the OECD initiated a new project on transfer pricing and intangibles. The stated reason for the project was that the OECD had experienced considerable difficulty with the treatment of intangibles in the business restructuring meetings. UPS and DSG are case studies for the application of transfer pricing rules in a business restructuring context where a critical element involves the transfer of an intangible. This paper considers how the arguments and outcomes in these cases inform the present discussion on transfer pricing and intangibles. UPS and DSG, when read in conjunction with the new OECD Guidelines on business restructurings, present a full range of analytical approaches to transfer pricing and captive insurance companies. There is Judge Ruwe’s sham transaction approach; there is the profit split approach followed in DSG; there is the possibility of CUPs and TNMMs; then there are the more recent approaches suggested by the OECD – transferring a going concern, and transferring an intangible asset. It will be interesting to see how the new OECD project on the Transfer Pricing Aspects of Intangibles will deal with question like this. It may well be that the answer to an intangible transfers may bring us back full circle to the return on capital profit splits from Grenada Industries and DSG.

A New International OECD Project on Learning: “Innovative Learning Environments”

A New International OECD Project on Learning: “Innovative Learning Environments”