First, mismatches in entity and instrument characterization.
Second, taxing profits from the delivery of digital goods and services.
Third, intra-group debt financing and captive insurance.
Fourth, transfer pricing.
Fifth, anti-avoidance measures.
And sixth, harmful preferential regimes.
Following up on that report on July 19, 2013,
the OECD released an action plan breaking down the key areas into
15 action points based on three core principles, gaps or mismatches,
frictions, and transparency, and two general additional work areas.
Since that time, the OECD has been working tirelessly publishing additional reports,
requesting public and expert feedback, etcetera, to meet its self-imposed
deadline of completing the work on the action items in December 2015.
Notably, the following changes are under consideration in
relation to the items which we discussed during this and the previous module.