New OECD data provides insight into MNE tax activity
July 10, 2020The OECD has published new data providing aggregated information on the global tax and economic activities of nearly 4,000 multinational enterprise (MNE) groups headquartered in 26 jurisdictions and operating across more than 100 jurisdictions worldwide. The data, released on July 8, is a major output based on the country-by-country (CbC) reporting requirements for MNEs under the base erosion and profit shifting (BEPS) project.
Cameco wins Canadian transfer pricing tax dispute
July 7, 2020Uranium producer Cameco has won a 12-year old transfer pricing tax dispute in Canada’s Court of Appeal. The Canada Revenue Agency (CRA) had appealed against a September 2018 decision of the Tax Court of Canada. That decision was unequivocally in Cameco’s favour in its dispute of reassessments issued by CRA for the 2003, 2005, and 2006 tax years.
Netherlands publishes much-awaited DAC6 guidance
July 1, 2020The Dutch government has published the much-awaited guidance on the country’s DAC6 reporting requirement. The guidance – published on June 30 – provides detailed explanations on cross-border arrangement, the definitions of intermediaries and relevant taxpayers, and the main benefit test, among others.
Irish tax authority extends DAC6 timelines by six months
June 29, 2020Irish Revenue has extended the DAC6 reporting timelines by six months. The DAC6 reporting law was scheduled to take effect on July 1. However, the date has now been extended in view of COVID-19 pandemic and in view of the EU Commission’s approval of an optional postponement of the reporting requirement in the EU.
US tax authority prioritizing projects for 2020-21
June 12, 2020The US Department of the Treasury and the US Internal Revenue Service (IRS) have invited recommendations for items to be included on the 2020-2021 Priority Guidance Plan.
Finland issues tax treaty guidance
June 9, 2020The Finnish Tax Administration has issued guidance on some of the common tax treaty provisions. The guidance – published on June 2 – comprises an article-by-article review of the provisions contained in a tax treaty and follows the order of the OECD Model Tax Convention.
