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10 Practical Tips To Manage (Tax Risk) And File Your Country-by-Country Report Before Year End!
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October 12th, 2017
No other Action of the OECD’s 15 Action Points will have wider consequences than Action 13 – “ Guidance on Transfer Pricing Documentation and Country by Country Report” – in terms of the data ammunition provided to tax authorities to perform tax risk assessment!
After issuing various guidance and handbooks since the roll out of the Final BEPS Action 13 in 2015, the OECD last week published additional guidance to BEPS Action 13: “ Handbook on effective tax risk assessment ” . This publication will assist tax authorities in carrying out tax risk assessment before embarking on a full-blown tax audit of the taxpayer.
The Netherlands Is Following The Cutting Tax Trend
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October 10th, 2017
Since October 5, 2017, the Dutch new cabinet successfully released the new tax plan in coming years. Several amendments are expected to be introduced to the present tax scheme, including changes on income tax, wealth tax and circulation tax (value added tax).
UN Releases Paper To Rise Attention To Digital Taxation
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October 10th, 2017
The United Nations published a paper on tax consequences of the digitalized economy, which gives an overview on possible issues for developing countries. It is a preparatory work for the Fifteenth Session of the Committee of Experts on International Cooperation in Tax Matters held in Geneva during October 17 to 20, 2017.
OECD - Feedback on PE Profit Allocation and Profit Splits Draft Released
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October 10th, 2017
The OECD released the public comments received on BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits. The two discussion drafts were issued on June 22, 2017 for public feedbacks, and a public consultation will be held on November 6 to 7, 2017 in Paris.
Luxembourg Benefits Amazon With €250 million State Aid
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October 5th, 2017
The European Commission released a decision, concluding that Luxembourg has granted undue tax benefits to Amazon of around €250 million. This decision is following up the investigation launched in October 2014, when the Commission looked into a series of tax ruling practices of Member States, including the Starbucks case in the Netherlands and the Fiat case in Luxembourg.
Tallinn Summit: A Tortuous Path to Digital Taxation
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October 5th, 2017
On September 29, the leaders of the EU Member States met at the Tallinn Summit, during which the leaders gave their opinions on the digital taxation on Union level . The tax plan has received endorsement from 19 out of the 28 states, but no new agreement was reached due to the fierce division of various parties.
Ireland Failed to Recover State Aid of €13 Billion from Tech Giant
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October 5th, 2017
The European Commission announced to bring Ireland to the Court due to its negative attitude in recovering the state aid from Apple. This decision is based on Art.108(2) TFEU, Art.16(3) of Regulation 2015/1589, and the Commission's recovery notice.
TPA Global Country Summaries Update
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October 5th, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
We updated the country summaries of.
Asia - Workshop “How BEPS impacts Value Chain Analysis for Transfer Pricing purposes”
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October 5th, 2017
We would like to invite you to our Value Chain Analysis Workshop in Kuala Lumpur, Malaysia on 3 October 2017 or Jakarta, Indonesia on 5 October 2017,
“How BEPS impacts Value Chain Analysis for Transfer Pricing purposes” .
IRS Releases List Of Countries Regarding Tax Information Exchange
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October 3rd, 2017
On September 29, 2017, the Internal Revenue Service (IRS) released Revenue Procedure 2017-46, providing a list of countries regarding tax information exchange. It will form part of Internal Revenue Bulletin (IRB) 2017-41, which is supposed to be issued on October 28, 2017.
Switzerland - Act on Country-by-Country Report Adopted
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October 3rd, 2017
The Federal Council adopted the Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals. The new act will enter into force on December 1, 2017, if the referendum is not called before expiry of its deadline on October 5, 2017.
OECD: Making Dispute Resolution More Effective - MAP Peer Review Report (NEW)
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October 2nd, 2017
The following BEPS related publications have been release by the OECD.
If you are interested in the theme covered by the books mentioned above, we invite you to visit www.
UK - Belarus Income Tax Treaty Ratified
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September 29th, 2017
The UK-Belarus Income Tax Treaty was signed between the Government of the United Kingdom of Great Britain, Northern Ireland and the Government of the Republic of Belarus. The new Treaty has not entered into force yet, and the UK-Soviet income treaty signed in London in 1985 will only cease to apply between the United Kingdom and the Republic of Belarus when the new treaty comes into force.
US - Revamp Of The Advanced Pricing Agreement Template
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September 29th, 2017
The IRS released a draft of the template used for advance pricing agreement (APA) for public discussion on revision. This template is designed to systematize how taxpayers propose terms for their APAs and standardize language used in executed APAs.
US - Tax Reform Framework Released With 20% CIT
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September 28th, 2017
On September 27, 2017, the White House released a framework for the US tax reform. The framework intends to both cut the income tax burden for taxpayers and slim the extremely sophisticated tax code in the US.
EU Commission - Path Set To Fair Tax On Digital Economy
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September 28th, 2017
The European Commission launched a new EU agenda to ensure that digital economy is taxed in a fair and growth-friendly way. The Commission also adopted a Communication, in which it sets out the challenges Member States currently face when it comes to acting on this pressing issue and possible solutions.
Transfer Pricing Under BEPS In Latin American And Caribbean Countries
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September 28th, 2017
The Inter-American Center of Tax Administrations (CIAT) recently reported the outcome of seven activities since 2014 to disseminate the content of the BEPS Action Plan. The countries gave their view on the level of priority of the different actions based on their respective contexts and shared their experience in applying BEPS reports, among which Actions 8 to 10 keep receiving the highest priority level.
Are US Bodies Terrified By The EU Unilateral Measure On Digital Economy?
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September 28th, 2017
Since the European Commission announced the tax reform plan to digital economies on union level on the Tallinn Digital Conference , it has received doubts and criticism about its impact on both economic growth and its efficiency, in particular, from the US bodies.
Economic Concerns .
Value Chain Analysis Event - Functional Analysis post BEPS
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September 25th, 2017
This event is provided jointly by TPA Global and Maastricht University.
As a result of the OECD’s BEPS Action Plan, MNEs are experiencing increased exposure to tax controversies if they are not simultaneously in control of their Operating and Transfer Pricing models.
The Netherlands: Amendments On Corporate Tax In 2018 Released
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September 21st, 2017
The Dutch government announced the Budget 2018, which includes the Tax Plan 2018 with several proposals. According to the document, there will be some amendments on the corporate tax law to be adopted starting January 1, 2018, unless otherwise indicated.
US: Concession On The Cutting Tax Reform
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September 21st, 2017
Last Wednesday, The US president Donald Trump reaffirmed his resolution to cut the federal corporate income to 15%, as was his promise during the campaign. However, such a low rate received more doubts and counterview than support.
Romania - Country Summary Update
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September 21st, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
Visit our country summary page .
Transfer Pricing Contributes Nearly £6 Billion To UK Tax
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September 19th, 2017
HMRC published the 2016/17 Transfer Pricing and Diverted Profits Tax Statistics, which shows the latest statistics data. The Transfer Pricing rules and the Diverted Profits Tax are important elements in a range of measures to make sure multinationals pay the right amount of tax on the share of their profits deriving from the UK.
EU - Oncoming Tax Rules On Digital Economy
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September 19th, 2017
The ministers of EU Member States reached a consensus on amending the existing international tax rules to plug the evasion of digital economy during the informal meeting of the EU Finance Ministers in Tallinn. Before the meeting, several Member States had proposed to update the taxing rules to collect a fair share from the digital giants, such as Estonia and the G4 countries .
Dutch Decree To Update Conditions For Business Reorganisation
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September 19th, 2017
The Dutch Ministry of Finance issued Decree No. 167217 to amend standard conditions for business re-organisations, including business mergers, legal divisions and legal mergers.
Your Tax Technology Plan
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September 18th, 2017
In the post-BEPS era, a surge in the number of deadlines to meet has led to an increase in the compliance burden. This, coupled with escalating disputes in numerous locations across the globe, leaves limited opportunities for cost savings and tax optimization.
Increasing Controversy For Offshore Structures After BEPS
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September 18th, 2017
A presentation on increasing controversy for offshore structures after BEPS.
Offshore (tax) planning structures have been used by multinational enterprises (MNEs) for decades.
Brazil-Argentina Treaty - Interpretation on Exemption of Dividend in Brazil
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September 14th, 2017
The Brazil Government published the Ruling 400/2017. The Ruling clarified that the exemption of dividend under Art.
Ireland - Corporate Tax Keeps Growing with Tax Rate Unchanged
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September 14th, 2017
A Government-commissioned report on the Irish tax scheme following the Apple Tax Ruling from the European Commission has been released. The report is given by economist Seamus Coffey, the chairman of the Government’s Fiscal Advisory Council.
OECD Report Releases Global Taxation Trends
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September 13th, 2017
On September 13, 2017, the OECD is released a new report on the worldwide tax reforms. This report is the second edition of the annual publication Tax Policy Reforms: OECD and Selected Partner Economies .
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