Transfer Pricing News, BEPS News & Analysis for MNEs
Transfer pricing news, BEPS news, and international tax news
International Tax Authority informs BVI Constituent Entities, that are part of Multinational Entity Group, that it will soon be ready to receive filings for CbC reporting.Continue Reading
The report would include CbC financial filings for the information, including profits, taxes, employees, and tangible assets – that these corporations already provide to the IRS on an annual basis.Continue Reading
The corrections are effective on February 19, 2020, and apply from December 6, 2019.Continue Reading
The definition of “significant global entity” to include members of large business groups headed by private companies, trusts, partnerships, investment entities, and individuals.Continue Reading
The OECD analysis shows that Pillar Two could raise a significant amount of additional tax revenues.Continue Reading
The report contains guidance on how the accurate delineation analysis applies to the capital structure of an MNE within an MNE group. Continue Reading
Comments must be received by March 6, 2020.Continue Reading
The “safe harbour” issue is included in the list of remaining work, but a final decision on this issue will be deferred until the architecture of Pillar One has been agreed upon.Continue Reading
Between 2019-2020, HMRC secured GBP 480 million through DPT investigations.Continue Reading
The webcast will be held on January 31, 2020, at 14:00-15:00 (CET).Continue Reading
The BEPS MLI will enter into force for these two countries on May 1, 2020.Continue Reading
The deadline for filing country-by-country reports and master files is December 10-23, 2020.Continue Reading
The BEPS MLI will enter into force for Liechtenstein on April 1, 2020.Continue Reading
The tax treaty applies from January 1, 2020.Continue Reading
The revised transfer pricing reporting threshold for 2020 is DOP11,552,402.Continue Reading
The additional interpretative guidance contains complete set of guidance concerning the interpretation and operation of BEPS Action 13 issued so far.
The OECD on December 23, 2019, released additional interpretative guidance on country-by-country (CbC) reporting.
The guidance is aimed at providing greater certainty to tax administrations and MNE Groups on the implementation and operation of CbC reporting requirement as culminated from the OECD’s work on base erosion and profit shifting (BEPS) Action 13.
It is clarified that, under the BEPS Action 13 minimum standard, the automatic exchange of CbC reports filed under local filing rules is not intended.
The December 23 document contains complete set of guidance concerning the interpretation and operation of BEPS Action 13 issued so far. The document will continue to be updated.
In addition, a summary of CbC reporting notification requirements in BEPS Inclusive Framework member jurisdictions has been posted on the OECD website. The summary is aimed at helping MNE Groups in complying with notification requirements in different jurisdictions where they have constituent entities.
The tax treaty will become effective after both countries have completed their respective domestic procedures.Continue Reading
By Professor William Byrnes (Texas A&M University School of Law)
The OECD will hold a public consultation meeting on December 9. Continue Reading
French Finance Minister, Bruno Le Maire, termed the US’ proposed action as unacceptable.Continue Reading
The Commission may bring the cases before the Court of Justice of the EU if Austria and Ireland do not act by February 1, 2020.Continue Reading
The tax treaty and Protocol implement the BEPS minimum standards to tackle tax planning strategies that exploit gaps and mismatches in tax rules.Continue Reading
International tax veteran Brian Abbey has joined Global Tax Management as Managing Director, International Tax.Continue Reading
Transfer pricing specialist Kevin Norton has joined Deloitte Ireland’s tax team as partner.Continue Reading
Earlier in July 2019, the US Trade Representative opened an investigation into whether the French DST is discriminatory in nature and harms US’ interests.
Continue Reading
The tax treaty will enter into force after both countries have completed their respective internal procedures.Continue Reading
Comments must be received by December 16, 2019.Continue Reading
The paper highlights the marked rise in corporation tax receipts and corporate profitability since 2014.Continue Reading
Any proposed tax must be levied on profits and not revenue, Amazon’s Vice President (Global Tax), Kurt Lamp, said.Continue Reading
Comments must be received by December 2.Continue Reading
The protocols contain an anti-abuse clause.Continue Reading
By Ritu Shaktawat (Partner, Khaitan & Co, India) and Sneh Shah (Senior Associate, Khaitan & Co, India)
The additional interpretative guidance will help MNE Groups in avoiding common errors made in preparing CbC reports.Continue Reading
Comments must be received by November 12, 2019. Continue Reading
For Denmark the BEPS MLI will enter into force on January 1, 2020.Continue Reading
By Ricardo Rendón (Partner, Chevez, Ruiz, Zamarripa y Cía, S.C., Mexico)
On September 8, 2019, the Executive Branch of the Mexican Government submitted to the Congress Tax Reform for 2020, which includes key tax changes to the country’s tax law primarily inspired by the OECD’s base erosion and profit shifting (BEPS) project.Continue Reading
By Catherine O’ Meara (Partner, Matheson, Dublin)
The Irish Government recently published a Transfer Pricing Rules Feedback Statement, which confirms that changes to the country’s transfer pricing rules and their implementation are forthcoming.Continue Reading
The rulings practically resulted in over 50 percent and in some cases up to 90 percent of those companies’ accounting profit being tax exempt.Continue Reading
According to the statistics, transfer pricing cases continue to take more time with average time being approximately 33 months (30 months in 2017).Continue Reading
Comments must be received by October 4, 2019.Continue Reading
Gurría also described the delivery of the OECD’s BEPS package in 2015 as one of the two “big bang” developments that transformed the global tax landscape in recent years.Continue Reading
Japan and Peru have “in principle” agreed to conclude a tax treaty.Continue Reading
The Protocol will be effective for requests for information made on or after the date of entry into force for tax years on or after January 1, 2009.Continue Reading
Amazon is a major UK employer and currently employs over 27,500 UK people. The company said that this number would increase to over 29,500 this year.
Continue Reading
Global law firm Shearman & Sterling has roped in Jay Singer as partner to the firm’s tax practice. Jay will be based in the firm’s Washington, D.C. office.Continue Reading
The tax authority is considering whether to appeal the decision.Continue Reading
The review reveals that countries have largely adopted their domestic CbC reporting rules in line with the BEPS Action 13 minimum standard.Continue Reading
The proposals would be included in Finance Bill, 2019 and, if enacted, would apply for chargeable periods commencing January 1, 2020.Continue Reading
Mandatory binding arbitration clause is included in the tax treaty protocols to resolve tax treaty disputes.Continue Reading
A former US Treasury international tax Counsel, Brian Jenn, has joined McDermott Will & Emery as its partner.
Jenn will be based out of the firm’s Chicago office.Continue Reading
Hong Kong issues guidance to ensure compliance with the country’s transfer pricing documentation requirements.Continue Reading
The BEPS MLI will enter into force in both countries on December 1, 2019.Continue Reading
By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Principal, Transfer Pricing Services, SKP Group)
On July 4, 2018, Hong Kong’s Inland Revenue Department passed the country’s final Inland Revenue (Amendment) (No. 6) Bill 2017, (the Amendment Bill).
This Amendment Bill (which became law on July 13, 2018) specified the documentary requirements from a transfer pricing perspective and also introduced measures to address various recommendations under BEPS Action Plans.Continue Reading
Austria proposes to impose a five percent digital tax to close tax loopholes and ensure that large digital corporations are called to account.Continue Reading
For Georgia the BEPS MLI will enter into force on July 1, 2019. Continue Reading
Armenia has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting.Continue Reading
Transfer pricing advisory Questro International has hired Chris Whitehouse as a transfer pricing partner for its Zurich office.
For Ireland, the BEPS MLI will enter into force in May 2019.Continue Reading
Hong Kong Inland Revenue Department has clarified that starting from April 2019, the Department will not accept voluntary filing of a country-by-country (CbC) report for an accounting period ended on or before March 31, 2018.Continue Reading
The treaty protocol provides for a low withholding tax rate of five percent for royalty and interest payments. An arbitration clause is also included to increase legal certainty for taxpayers.Continue Reading
Transfer pricing specialist Questro International has hired Manuel Koch as a Partner for the firm’s office in Stuttgart, Germany.
Koch brings significant experience of over ten years specialization in transfer pricing consulting. Koch has wide experience in international tax planning engagements for international corporates including holding and principal structures as well as Swiss finance branches and IP boxes.Continue Reading
Global advisory firm Duff & Phelps has announced that Jill Weise will succeed Michael Heimert as the Global Leader for the firm’s transfer pricing practice.
Weise has nearly 25 years of expertise in transfer pricing. She previously served as the firm’s transfer pricing practice leader for North America.
Continue Reading
The Commission is looking into five tax rulings issued by the Dutch tax authority to Nike group companies in the Netherlands between 2006 to 2015.Continue Reading
By Maulik Doshi (Partner, Head of Transfer Pricing & International Tax, SKP Group) and Kamlesh Kaltari (Senior Manager, SKP Group)
In India, the 2016 Finance Act introduced a three-tiered transfer pricing documentation regime with a view to aligning the Indian transfer pricing documentation rules with Action 13 of the OECD’s base erosion and profit shifting (BEPS) project.
Accordingly, Indian subsidiaries of multinational groups were required to comply with new “master” and “local” files requirements and a new country-by-country reporting requirement from the 2016-17 financial year.Continue Reading
Transfer pricing expert Mark Madrian has joined Valentiam Group as a Partner in the firm’s West Coast practice.
Madrian has advised clients on complex cross-border transfer pricing and other international tax issues. He was recently recognized as a Leading Transfer Pricing Adviser by Legal Media.
Continue Reading
The treaty will be effective from April 1, 2019.Continue Reading
By Anas Salhieh (Senior Tax Executive, Al Tamimi & Company, Riyadh, Saudi Arabia)
Saudi Arabia’s General Authority for Zakat and Income Tax has published for public comments draft transfer pricing bylaws as part of the Kingdom of Saudi Arabia’s commitment to the OECD’s base erosion and profit shifting (BEPS) project.Continue Reading
Cook Islands has newly joined the OECD’s Inclusive Framework on base erosion and profit shifting.Continue Reading
The new anti-abuse measures entered into force on January 1, 2019.Continue Reading
Jeffrey Tate has joined US law firm Arent Fox’s tax practice as a Partner.
The BEPS MLI will enter into force for Singapore on April 1, 2019.Continue Reading
Gibraltar must recover unpaid taxes of around EUR100m from companies that benefited from the corporate tax exemption regime for interest and royalties as well as from the five tax rulings.Continue Reading
In the 2015-16 income year, the estimated tax gap for large corporate taxpayers was 4.4 percent, as compared to 5.8 percent tax gap in the 2014-15 income year.Continue Reading
The OECD has made 60 jurisdiction-specific recommendations on issues such as improving the timeliness of the exchange of information and ensuring that exchanges of information are made with respect to preferential tax regimes that apply to income from intellectual property.Continue Reading
By Elizabeth Sidi (Senior Tax Consultant, PwC, Bulgaria)
Bulgaria is introducing new interest limitation rules and a new controlled foreign corporation regime from January 1, 2019.
Continue Reading
Important process of ratifying the BEPS MLI is on. In 2019-2020, the provisions will come into effect, says Akhilesh Ranjan.
Continue Reading
The legislation is intended to enter into force in July 2019. Continue Reading
According to IMF Chief Christine Lagarde, governments should figure out a world-wide answer on tax.Continue Reading
The legislation seeks to incorporate the OECD’s proposals under Action 5 of the base erosion and profit shifting (BEPS) project, on countering harmful tax practices, as well as the new EU substance requirements.Continue Reading
By Catherine O’ Meara (Partner, Matheson, Dublin) and Brian Doohan (Senior Associate, Matheson, Dublin)
On November 27, 2018, Ireland’s Finance Minister Paschal Donohoe announced the details of a Competent Authority Agreement between Ireland and Malta (Agreement). The clear aim of the Agreement is to end what is referred to as the “Single Malt” tax structure.Continue Reading
France and Germany urged the EU Council to adopt the proposed digital services tax by March 2019.Continue Reading
By Bram Markey (Director, Transfer Pricing, PwC Belgium)
The Belgian tax authority has issued a draft Circular on the 2017 update to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.Continue Reading
Qatar is the 85th jurisdiction to sign the BEPS Convention, which now covers nearly 1,500 bilateral tax treaties.Continue Reading
An arbitration clause is included in the new tax treaty to resolve double taxation disputes.Continue Reading
The majority of the Board of Directors’ meetings must be held in Mauritius, or the executive management of the company must be regularly exercised in Mauritius.
The tax treaty provides for a low withholding tax rate of five percent for dividend payments. Interest, royalties, and fees are subject to a low withholding tax rate of ten percent.Continue Reading