BEPS
Tax Technology Event 2017 - From ‘Staying Out Of Trouble’ To ‘Being In Control’
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July 25th, 2017
This workshop is organized to assist businesses in finding their way through the world of tax technology solutions.
Thursday, 7 September 2017
BEPS Action 8 on Hard-to-Value Intangibles: is this the last piece of the puzzle required by SARS to issue its updated Transfer Pricing Practice Note?
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July 19th, 2017
One of the main action items identified by South Africa’s National Treasury in its summary of the country’s position on the G20/Organisation for Economic Co-operation and Development (“OECD”) action plan on base erosion and profit shifting (“BEPS”), is the requirement for the South African Revenue Service (“SARS”) to update the Transfer Pricing Practice Note in line with the OECD Transfer Pricing Guidelines to include new guidance on the arm’s length principle and an agreed approach to ensure appropriate pricing on intangibles that are difficult to value.
Action 8 of the BEPS Action Plan mandated the development of transfer pricing rules or special measures for the transfer of Hard-To-Value Intangibles (“HTVI”) and the general rules of how to deal with HTVI can be found in section D.
Reminder - Mandatory CbC Reporting Notification In The Netherlands Before 1 September 2017
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July 17th, 2017
As of 1 January 2016 local Dutch entities, belonging to a multinational group that meets the threshold for Country-by-Country Reporting, must notify the Dutch tax authorities (“Belastingdienst”) of the identity and the tax residence of the Reporting Entity no later than the last day of the reporting fiscal year of such multinational group. For the first calendar year 2016 and fiscal years starting in financial year 2016 and ending later but before or on 31 August 2017, the notification deadline has been extended to 1 September 2017.
Managing Controversy after BEPS
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July 14th, 2017
Has BEPS increased the risk of tax controversy?
Yes, the lack of clarity around the implementation of the BEPS Action Plans by countries is invariably leading us to a world of unavoidable tax disputes. It is increasingly difficult to wholly identify and comply with all the legislative norms applicable to corporate taxpayers in today’s post-BEPS world.
OECD Releases 2017 Transfer Pricing Guidelines
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July 13th, 2017
The OECD released the 2017 Edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. Based on the 2010 Transfer Pricing Guideline, the updated edition provides guidance on how to apply the Arm’s length principle under BEPS context.
OECD Publishes MLI Matching Database In Beta Version
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July 11th, 2017
The OECD published its “MLI Matching Database” for tax treaties in beta in a preliminary (beta) version. The database makes projections on how the MLI modifies a specific tax treaty covered by the MLI by matching information from Signatories’ MLI Positions.
OECD - This week's updates on BEPS
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July 7th, 2017
This week the OECD launched some important announcement regarding BEPS:
OECD, CREDAF and UNDP hold a regional meeting of the Inclusive Framework on BEPS for French speaking countries
EU Parliament Approves Proposal On Tax Transparency
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July 6th, 2017
The EU parliament approved the proposal to amend Directive 2013/34/EU on disclosing the financial information of multinationals for tax purpose, including branches outside the EU.
Threshold for Country-by-Country report
PANA Publishes Draft Report And Draft Recommendation
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July 5th, 2017
On June 30, the draft inquiry report that provides conclusions identifying contraventions of EU law and instances of maladministration and the draft recommendations of the PANA Committee were published. On the same day, the European Parliament provided Briefing on EU Legislation in Progress regarding public country-by-country reporting.
OECD Addresses Tax Issues During Tax Talk #6
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June 27th, 2017
The OECD held Tax Talks #6 addressing the Inclusive Framework on BEPS and other related subjects. The OECD officials said an important update to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations will be released soon.
PANA Committee To Discuss Anti-Money Laundering Directive
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June 27th, 2017
EU's Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) scheduled a meeting on July 3, 2017 with Věra Jourová, European Commissioner for Justice, Consumers and Gender Equality , who is in charge of anti-money laundering (AML) policy in the Commission.
Beneficial Ownership
PANA To Address Financial Intelligence Units And The "Russian Laundromat Case"
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June 15th, 2017
On June 21, the Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) will hold a meeting on "Financial Intelligence Units (FIUs) – Ins and Outs, and the Russian Laundromat case".
Bank records
OECD Requests Feedback On Dispute Resolution Peer Reviews
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June 13th, 2017
The OECD informed it invites taxpayers to answer questions regarding specific issues related to access to the Mutual Agreement Procedure (MAP), clarity and availability of MAP guidance and the timely implementation of MAP agreements for the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore and Spain.
Background: MAP
EU JURI and PANA Committee To Hold Hearing On The Protection Of Whistleblowers
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June 13th, 2017
On June 21, the Members of the EU Committee on Legal Affairs (JURI) and PANA Committee will hold a hearing with experts on legitimate measures to protect whistle-blowers acting in the public interest when disclosing the confidential information of companies and public bodies.
Protection for whistleblowers
Members of European Parliament Adopt Public Cbc Reporting With A "Safeguard Clause"
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June 13th, 2017
On June 12, MEPs from the economic affairs and legal affairs committees voted for a public Country-by-Country (CbC) reporting draft directive implementing a 'safeguard clause'. The clause will allow increased tax transparency but ensure no disruption in fair competition by preventing sensitive information to be shared publicly.
Cayman Islands Committed to BEPS Because Of Reputational Reasons
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June 9th, 2017
On June 7, over 70 countries and jurisdictions have signed, or formally expressed their intention to sign, an innovative multilateral convention. According to former Minister for Cayman's Financial Services Wayne Panton, the effects of the BEPS project on Cayman are relatively “benign,” but the government committed to the initiative “for reputational reasons,” Cayman Compass reported.
U.S. and South Africa to Exchange CbC Reports
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June 6th, 2017
On June 5, the South African Revenue Service (SARS) released the text of an arrangement between the United States of America and the Republic of South Africa on the exchange of Country-by-Country (CbC) Reports.
Exchange of Country-by-Country Reports
Thailand Joins The Inclusive Framework On BEPS And Participates In First Joint Programme For The Implementation Of International Tax Standards
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June 4th, 2017
Thailand has become the 98th jurisdiction to join the Inclusive Framework on BEPS ("IF") and will participate on an equal footing with all other IF members at the next plenary meeting of the IF that will be held on 21-22 June 2017 in Noordwijk, the Netherlands.
The IF was established in January 2016, after the G20 Leaders urged the timely implementation of the BEPS package released in October 2015 and called on the OECD to develop a more inclusive framework with the involvement of interested non-G20 countries and jurisdictions, including developing economies.
PANA Committee Meets EC President Juncker
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June 1st, 2017
On May 30, The PANA committee held a hearing with European Commission President Jean-Claude Juncker, stating that a draft law that targets accountants and lawyers running tax-avoidance schemes will be made available before the end of June. The EC President was also accused of helping tax avoidance schemes during his period of Prime Minister and Finance Minister of Luxembourg.
EU Council Adopts Directive On Hybrid Mismatches With Third Countries (ATAD2)
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May 31st, 2017
The EU Council adopted the rules to close down hybrid mismatches with the tax systems of third countries (ATAD 2), which aims to prevent corporate tax avoidance and contributes to the implementation of OECD's base erosion and profit shifting (BEPS) measures.
Hybrid Mismatch Arrangements
OECD releases peer review document for assessment of the BEPS Action 6 minimum standard
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May 29th, 2017
Today the OECD released the key document, approved by the Inclusive Framework on BEPS, which will form the basis of the peer review of the Action 6 minimum standard on preventing the granting of treaty benefits in inappropriate circumstances.
The Action 6 minimum standard is one of the four BEPS minimum standards.
BEPS Project Potentially Harmful To Asset Management Industry
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May 29th, 2017
During a panel discussion at the Guernsey Funds Forum in London, tax experts warned that the asset management industry could be harmed by the proposed Base Erosion and Profit Shifting (BEPS) project. The experts warned that the rules ignore how the asset management industry works and that every country has its own version of what BEPS really means.
China Further Develops Its Transfer Pricing Regime - Issuance Of Bulletin 6
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May 22nd, 2017
The China State Administration of Taxation (SAT), on March 17, 2017 has issued new transfer pricing rules: Bulletin 6 – the “Administrative Measures on Special Tax Investigation, Adjustment and Mutual Agreement Procedures”, which has taken effect as of May 1, 2017. Bulletin 6 revised and refined certain provisions stipulated in the 2009 "special tax adjustment implementation measures (Trial)" (Circular 2) and further clarified the transfer pricing investigation procedures and adjustment methods applied by the Chinese tax authorities.
German Finance Minister Claims Malta Has Become The Panama Of Europe
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May 11th, 2017
Germany's North Rhine-Westphalia finance minister Norbert Walter-Borjans claimed that Malta has become the Panama of Europe after a data leak revealed by German Journalists that there are 70,000 offshore companies in Malta. In response, Ministry of Finance informed that public register can be accessed online while its Finance Minister Edward Scicluna tweets "Pull another one".
The United Arab Emirates Sign The Multilateral Convention On Mutual Administrative Assistance in Tax Matters
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April 26th, 2017
On April 21, the OECD informed that the United Arab Emirates signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. By doing so, the United Arab Emirates became the 109th signatory to the convention.
The implementation Of BEPS Action Plan 13 In LATAM
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April 7th, 2017
The implementation of BEPS Action Plan 13 in LATAM
Tax administrations and international economic organizations have reached consensus for implementing international measures that will promote tax transparency amongst the business community.
UN Discusses International Cooperation In Tax Matters
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April 4th, 2017
During its 14th session run on 3 - 6 April, the UN Committee of Experts on International Cooperation in Tax Matters released several documents including modifications to the UN Model Double Taxation Convention between Developed and Developing Countries and draft guidance on transfer pricing issues in Extractive industries.
BEPS Changes to UN Model DT Convention
Technology Solutions In A Post-BEPS World
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April 4th, 2017
There has been a complete paradigm shift in global taxation with the rise in audit risks caused by new global initiatives like the OECD’s BEPS Project.
JD Choi, CEO at Tax Technologies and TPA Global Member, explores the technology solutions that should be administered to mitigate these audit risks in a post-BEPS world.
UK Amends Country-By-Country Reporting
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March 31st, 2017
On March 30, the UK Her Majesty’s Revenue & Customs (HMRC) published amendments to Country By Country (CbC) reporting that extend the original statutory requirements to partnerships and adds new obligations for UK entities.
Updates
Exposing The Real Economic Activity Of European Banks
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March 28th, 2017
On March 27, Oxfam published a report based on an analysis of Country-by-country reporting data exposing Europe’s 20 biggest banks that are registering over a quarter of their profits in tax havens, but just 12% of their revenue and 7% of their employees.
Oxfam Report
OECD Publishes Report On Tax Certainty And Other Subjects
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March 21st, 2017
The OECD published an OECD Secretary-General Report to G20 Finance Ministers that consists of the latest developments in the international tax agenda and an IMF/OECD report for G20 finance ministers on tax certainty. The report also includes a Progress Report to the G20 by the Global Forum on Transparency and Exchange of Information for Tax Purposes.
EU Report: "The US Emerging as Tax and Secrecy Haven Leader"
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March 13th, 2017
The European Parliament’s Inquiry Committee into Money Laundering, Tax Evasion and Tax Avoidance (PANA) published in-depth analysis on EU-US trade and investment relations and their impact on tax evasion, money laundering and tax transparency. One day earlier, the PANA Committee also held its third and last public hearing on “the role of intermediaries in the Panama Papers”.
Malaysia Joins BEPS Inclusive Framework
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March 8th, 2017
The OECD announced that Malaysia has joined the “Inclusive Framework on BEPS." Malaysia commits to the BEPS Project to participate as a BEPS Associate of the OECD's Committee on Fiscal Affairs.
IRS Released Draft Instructions for Filing CbC Reports
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February 28th, 2017
The IRS published instructions for filing Form 8975 and accompanying the draft Schedule A (Country-by-Country Report) that apply to US multinational companies with more than $850 million in annual consolidated gross income.
Background: IRS Reports
BEPS Action 4: Policy Considerations and Implementation Status
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February 27th, 2017
This article addresses BEPS Action 4. The authors provide a historical perspective of the relevant BEPS and EU measures, explain the highlights of BEPS Action 4, discuss the overlap between the different Actions, update readers on countryspecific implementation of BEPS Action 4, summarize existing case law in the area, present practical examples dealing with the impact of Action 4 on certain structures and, finally, provide concluding remarks.
Adoption of the CUP Method for Commodity Transactions in new Colombian Tax Law
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February 24th, 2017
The recent tax reform -issued by Law 1819 of December 29/2016- introduced some changes in international tax law and transfer pricing rules. Relevant changes were adopted to introduce CbC report, adopt CFC legislation and define a legal framework regarding preferential tax regimes and beneficial owner to control base erosion and prevent tax deferral (see BEPS Action 5).
Irish Department of Finance Seeks Feedback On Corporate Tax Code
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February 24th, 2017
The Irish Department of Finance released public consultation paper seeking public feedback in connection with a review of Ireland’s Corporation Tax Code. The Government appointed an independent expert, University College Cork economist Seamus Coffey, to review Ireland's corporate tax code using the information collected during the public consultation.
"EU made fundamental errors in State Aid Decision"
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February 22nd, 2017
On February 20, the EU published arguments of Apple’s appeal against the EU Commission’s State Aid Decision of August 30, 2016, in which the Commission concluded that Ireland gave illegal tax benefits to Apple worth 13 billion Euro. The tech giant says EU made fundamental errors in interpreting the way in which Apple generated its profits.
Irish Minister of Finance Addresses Corporate Tax
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February 17th, 2017
During the Plenary Session on February 16, Irish Minister for Finance Michael Noonan addressed the recent development of international taxation and problems with aggressive tax practices. Minister praised OECD BEPS project, but warned against the EU efforts that deviate from BEPS recommendations.
A Simplified Guide to Increasing your Chances of Survival in Battles with Tax Authorities
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February 14th, 2017
Multinational enterprises (MNEs) have been facing disputes on tax and/or transfer pricing with tax authorities since their very inception. In light of the Base Erosion and Profit Shifting (BEPS) Action Plan of the OECD and the many UN initiatives to set new norms for tax and transfer pricing, many tax authorities around the globe will use the grey areas in these plans to challenge as many tax structures as they can, sometimes leading to nothing more than pure aggressive behavior.
EU Council Releases Presidency Draft Roadmap on BEPS
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February 11th, 2017
The European Council released a Draft EU-BEPS Roadmap by the Maltese Presidency of the Council setting out future work in the coming months. The roadmap addresses subjects such as hybrid mismatches, dispute resolution mechanism, the list of non-cooperative jurisdictions, renewed CCCTB, Patent Boxes, Code of Conduct (Business Taxation) and the Mandatory Disclosure rules.
TP Alert in Indonesia
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February 7th, 2017
As tax administrations and international economic organizations reach consensus for implementing international measures that will promote tax transparency amongst the business community, uncertainties rise around the scope and extent of some of the action points proposed to drive tax transparency between jurisdictions. For example, the implementation of Action plan 13.
OECD Invites Multinationals For Feedback On MAP Peer Reviews
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January 31st, 2017
On January 30, OECD invited multinationals to provide input on the Mutual Agreement Procedure (MAP) peer review and monitoring process, which was launched in December 2016 under Action 14 of the BEPS Action Plan. At this stage, OECD gathers input on Austria, France, Germany, Italy, Liechtenstein, Luxembourg and Sweden.
USA - GAO Analyzed Potential Impact of BEPS
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January 31st, 2017
On January 27, the Government Accountability Office published a report that examines the potential impact of the OECD BEPS initiative’s revised international transfer pricing guidance on both the IRS and U.S.
Seven More Jurisdictions Join The Automatic Sharing of CbC Reporting
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January 27th, 2017
On January 27, the OECD informed that Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the Russian Federation have now signed the Multilateral Competent Authority Agreement for Country-by-Country Reporting (CbC MCAA), bringing the total number of signatories to 57.
Background: CbC Reporting for Tax Transparency
Draft Toolkit On The Lack Of Comparables Released For Comments
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January 27th, 2017
On January 24, 2017 the so-called Platform for Collaboration on Tax (a joint initiative of the IMF, OECD, UN and World Bank Group) published a Discussion Draft on the Toolkit for Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses, which addresses the ways developing countries can overcome a lack of data on "comparables."
Background
Representation before tax authorities and Courts
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January 24th, 2017
Multinational enterprises (MNEs) have been facing disputes on tax and/or transfer pricing with tax authorities since their very inception. Over the course of time, a wide variety of instruments have been developed in order to address these disputes.
IRS Released A New Withholding Agreement And CbC Filing Guidance
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January 23rd, 2017
US IRS released an updated withholding foreign partnership agreement (WP agreement) and a withholding foreign trust agreement (WT agreement). The IRS also published an advance version of the Revenue Procedure 2017-23 addressing the process for filing the Country-by-Country (CbC) Report and other related documentation by ultimate parent entities of U.
India and Kazakhstan Amend Existing DTA
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January 6th, 2017
On January 6, The Central Board of Direct Taxation (CBDT) announced that India and Kazakhstan have signed a protocol to amend the existing Double Taxation Avoidance Agreement.
Amended DTA in line with BEPS
Cyprus calls for notification from MNEs with regards to Country-by-Country reporting
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January 6th, 2017
On December 30, 2016, the Ministry of Finance in Cyprus published a Decree regarding country-by-country reporting for multinational enterprises.
Country-by-Country Reporting
Peru - "Sixth Method" provisions are being replaced by other approach that seems more in line with Arm´s Length Principles
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January 3rd, 2017
On Saturday, December 31, 2016 Government published Legislative Decree 1312, in the Official Gazette Decree that modifying parts of the Income Tax, particularly related to Transfer Pricing:
Amends in paragraph 1 of point e) article 32-A of the Income Tax Law. Basically most of the "Sixth Method" provisions are being replaced by other approach that seems more in line with Arm´s Length Principles.
German Federal Council Adopts BEPS Legislation
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December 20th, 2016
The German Federal Council approved Country-by-Country Reporting and other BEPS related measures. These were approved by the Federal Parliament earlier on December 2 after several months of discussions on the approval of specific measures.
New Zealand To Update TP And Permanent Establishment Measures
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December 16th, 2016
On December 14, the Minister of Revenue Michael Woodhouse has released information on BEPS measures being considered by the Government that would strengthen the transfer pricing and permanent establishment rules to address base erosion and profit shifting (BEPS).
Background
France Rejects Public Country-by-Country Reporting
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December 14th, 2016
On December 9, France’s Constitutional Council rejected public country-by-country reporting as it violated the freedom of enterprise guaranteed under the French Constitution.
Background: CbC Reporting in France
OECD Discusses New Guidance on CbC Implementation
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December 6th, 2016
During a OECD BEPS webcast on December 5, senior members from the OECD's Centre for Tax Policy and Administration (CTPA) discussed BEPS related issues and further OECD's tax agenda. The CTPA addressed guidance on implementation of Country-by-Country (CbC) reporting, which was released on the same day.
Singapore Issues e-Tax Guide for Country-by-Country Reporting
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October 13th, 2016
The Inland Revenue Authority of Singapore (IRAS) issued an e-Tax Guide on Country-by-Country Reporting. Singapore-headquartered MNEs meeting certain conditions are required to prepare and file CbC Reports to the IRAS for financial years beginning on or after January 1, 2017.
BEPS and Transfer Pricing in MNCs: Policy Considerations and Practices
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October 11th, 2016
The changes proposed by the OECD BEPS Action Plan in October 2015 have the potential to substantially challenge the whole tax and transfer pricing landscape for many taxpayers. More specifically, with a radical attack on preferential regimes and tax avoidance schemes and enhanced transparency through, for example, for example, Country-by-Country (“CbC”) reporting, tax authorities and other governmental units will be able to understand and where appropriate challenge how MNEs allocate their profits and taxes globally.
Tax Risk Management & Transfer Pricing for Life Sciences
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September 22nd, 2016
As regulations around the world become both more numerous and stringent, and enforcement and penalties increase in the highly regulated life sciences sector, companies may benefit from taking a risk-based approach to tax planning compliance, execution, and tracking.
The conference agenda will focus on the most problematic areas in tax risk management such as tax compliance and governance, transfer-pricing and country-by-country reporting issues management and others:
New Course: Transfer Pricing – BEPS for Beginners
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September 14th, 2016
e-Bright and TPA Global have launched the 4th course of the Transfer Pricing courses
‘BEPS for Beginners’
OECD to Hold First 'Inclusive Framework for BEPS Implementation' Meeting
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September 7th, 2016
On June 30 and July 1, representatives of countries and jurisdictions worldwide will gather in Kyoto, Japan, for a first meeting of the inclusive framework organized to take forward the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project.
Governance, Structure and Work Program
OECD Publishes Comments On Amendments To Chapter IX TP Guidelines
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August 26th, 2016
On August 24, The OECD published the comments it received on the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines, "Transfer Pricing Aspects of Business Restructurings."
Background
OECD Releases Discussion Draft On Branch Mismatch (Action 2)
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August 24th, 2016
The OECD invited interested parties to provide comments on branch mismatch structures under Action 2 (Neutralizing the Effects of Hybrid Mismatch Arrangements) of the BEPS Action Plan.
Background
OECD Releases Discussion Draft On Branch Mismatch (Action 2)
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August 24th, 2016
The OECD invited interested parties to provide comments on branch mismatch structures under Action 2 (Neutralizing the Effects of Hybrid Mismatch Arrangements) of the BEPS Action Plan.
Background
BEPS implemented into the LATAM countries: what is happening in that region?
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August 4th, 2016
In the case of LATAM countries the majority are not OECD members and their contribution to BEPS measurements has been limited. Nevertheless, some LATAM countries already have or have announced to implicitly or explicitly implement regulations that are anti-BEPS.
OECD - Discussion Draft on Action 4 in the Banking and Insurance Sectors
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August 3rd, 2016
The OECD invited interested parties to provide comments on a discussion draft which deals with approaches to address BEPS involving interest in the banking and insurance sectors under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Action 4 - Background
OECD - Discussion Draft on Action 4 in the Banking and Insurance Sectors
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August 2nd, 2016
The OECD invited interested parties to provide comments on a discussion draft which deals with approaches to address BEPS involving interest in the banking and insurance sectors under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Action 4 - Background
Insights into BEPS Implementation By MNEs
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July 22nd, 2016
A new 2016 Global BEPS Readiness Survey examined how multinational enterprises are reacting to and preparing for the BEPS, revealing problems multinationals have adjusting to the new rules. The findings uncovered trends, revealed risks and exposed pain points on a global scale.
Insights into BEPS Implementation By MNEs
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July 21st, 2016
A new 2016 Global BEPS Readiness Survey examined how multinational enterprises are reacting to and preparing for the BEPS, revealing problems multinationals have adjusting to the new rules. The findings uncovered trends, revealed risks and exposed pain points on a global scale.
Jamaica Joins Inclusive Framework on BEPS Implementation
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July 21st, 2016
The OECD announced that Jamaica has become the 85th member of the Inclusive Framework on BEPS Implementation. The OECD informed that more countries that attended the Kyoto meeting on June 30, are expected to join the Framework.
OECD Releases Discussion Draft on Group Ratio Rule (Action 4)
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July 11th, 2016
On July 11, the OECD invited interested parties to provide comments on a discussion draft which deals with elements of the design and operation of the group ratio rule under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Fixed Ratio Rule
OECD Releases Two Discussion Drafts on BEPS Actions 7 and 8 - 10
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July 6th, 2016
The OECD has released BEPS discussion drafts on attribution of profits to permanent establishments, which deals with work in relation to BEPS Action 7, and revised guidance on profit splits, which deals with work in relation to BEPS Actions 8-10.
Discussion Draft - Action 7
OECD Releases Guidance on the Implementation of CbC Reporting
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July 1st, 2016
The OECD has released guidance on implementing country-by-country (CbC) reporting, as set out in Action 13 Report “Transfer Pricing Documentation and Country-by-Country Reporting” of the base erosion and profit shifting (BEPS) project.
Country-by-Country Reporting
How to make intercompany loans BEPS proof
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March 17th, 2016
In this article we provide four “true or false” statements on how the intercompany debt financing has become vulnerable and how to resolve the transfer pricing issues around that.
Debt as intercompany financing with excessive interest deductions has come under greater scrutiny of the tax authorities after the OECD published its final work on Action Points relating to intercompany financing in October last year.
Dissecting BEPS Action Plan 6 Preventing The Granting Of Treaty Benefits In Inappropriate Circumstances
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December 10th, 2014
Action Plan 6 of the BEPS Action Plan identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns.
The most important aspects of the report are :
Specialties
Country expertise
Industries
BEPS
May 10th, 2016
BEPS
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May 10th, 2016

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