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OECD lists countries agreeing to country-by-country reporting exchange
The OECD today released an updated list of automatic exchange relationships established between tax authorities to implement country-by-country reporting under Action 13 of the OECD/G20 base erosion profit shifting (BEPS) plan. The OECD also announced activation of automatic . . .
Featured News
New UN extractives industry guidance note analyzes value chain for mining, oil and gas
US transfer pricing lawyers Robert Feinschreiber & Margaret Kent examine a guidance note, released last week by the UN’s Committee of Experts on International Cooperation in Tax Matters, which concerns transfer pricing issues associated with extractive industries, specifically mining and mineral extraction and oil and natural gas production . . .
Europe
EU proposals for public country-by-country reporting, CCCTB should be rejected, Irish finance minister says
Ireland’s Minister for Finance Michael Noonan today expressed opposition to EU Commission proposals for a common consolidated corporate tax base (CCCTB) and public country-by-country reporting, arguing that both measures are counterproductive . . .
Americas
Bermuda, Kazakhstan, Côte d’Ivoire join BEPS group fighting cross-border tax avoidance
Bermuda, Kazakhstan, and Côte d’Ivoire have joined the “Inclusive Framework on BEPS,” to combat multinational enterprise tax avoidance and to better resolve cross-border tax disputes. By joining the framework, the countries have pledged . . .
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World Bank publishes transfer pricing handbook for developing countries
Joel Cooper of DLA Piper discusses a new World Bank handbook designed to assist developing country tax administrations with the implementation of transfer pricing rules. . .
Europe
Asia-Pacific
Australia: country-by-country reporting exemption guidance offers relief to MNEs
The Australian Taxation Office (ATO) has issued guidance for multinational groups on how to apply for an exemption from the obligation to provide some or all of the information in required tax statements known as . . .
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OECD releases discussion drafts on attribution of MNE profits to permanent establishments and profit splits
The OECD today released two discussion drafts on international tax standards that deal with allocating multinational corporation profits between tax jurisdictions: guidance on the attribution of profits to permanent establishments (PEs) and proposed revisions to guidance on profit splits under the OECD . . .
Austria
EU finance ministers split on public release of multinational corporation tax data
Dutch finance minister and president of the Eurogroup, Jeroen Dijsselbloem, expressed support for a proposal that would mandate public release of country-by-country tax data on multinationals, while finance ministers from Malta, Belgium, and Austria . . .
Europe
Germany details tax rules for international businesses with permanent establishments
Tax specialist, Ninja-Antonia Reggelin, reviews a new German circular providing comprehensive guidance on the allocation of profits between a business and a foreign permanent establishment . . .
Americas
Europe
UK finalizes country-by-country reporting rules for multinationals
The UK on February 26 issued final rules requiring large UK-parented multinationals and some UK subsidiaries of large multinationals to file annual country-by-country reports to HM Revenue and Customs (HMRC). The regulations finalize draft regulations on the topic . . .
Australia
31 nations sign agreement on exchange of country-by-country transfer pricing reports
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting . . .
Featured News
Part two: international tax consultation on “digitalization” draws 50 speakers (pillar two)
Part two of two. This article summarizes discussion of the “pillar two” proposals at the OECD digitalization consultation, held March 13–14 in Paris. The pillar two proposals, described in a February 13 OECD discussion draft, call for global adoption of a minimum tax and a tax on base eroding payments. . . .
Europe
Americas
Europe
Americas
Wheaton settles transfer pricing dispute with Canada Revenue agreeing to increase service fee charged to foreign subsidiary: Wheaton Precious Metals→
Wheaton Precious Metals™ Corp. (“Wheaton” or the “Company”) is very pleased to . . .
More: Mining.com, Streetwise Reports.
Asia-Pacific
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Asia-Pacific
Asia-Pacific
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Asia-Pacific
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Europe
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2017 UN transfer pricing manual released, changes approved for model tax treaty
The UN’s Committee of Experts on International Cooperation in Tax Matters (UN Committee), during meetings held last week, released its revised and updated 2017 United Nations Practical Manual on Transfer Pricing for Developing . . .
Europe
Asia-Pacific
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OECD: peer review for BEPS minimum standards released
The OECD today released documents to implement peer review of countries’ compliance with minimum standards devised under OECD/G20 base erosion and profit shifting (BEPS) Action 13, dealing with country-by-country reporting, and . . .
Europe
France: public county-by-country reporting declared unconstitutional
The French Constitutional Council, December 8, ruled that sections of a law establishing public country-by-country reporting by multinationals are contrary to the Constitution, writes Davide Anghileri of the University of Lausanne . . .
Asia-Pacific
Australia steps up effort to combat corporate tax avoidance through offshore hubs, other schemes
The Australian Taxation Office (ATO) has intensified its efforts to crack down on multinational corporation tax avoidance, launching a consultation on the aggressive use of offshore hub structures, and issuing taxpayer alerts on offshore permanent establishments . . .
Europe
Americas
Europe
Draft German tax law adopts low threshold for transfer pricing master file, combats MNE tax avoidance
Tax specialist, Ninja-Antonia Reggelin, discusses a proposed new German tax law to combat multinational profit shifting, which includes implementation of transfer pricing documentation and country-by-country reporting and exchange of tax rulings, as well as several other measures. . .
Americas
US group urges Congress to cut OECD funding, claims US harmed by BEPS international tax standards
Representatives about 20 US advocacy groups, in a May 12 letter, urged Congress to stop funding the OECD, arguing that its work developing worldwide standards to tax multinational . . .
Americas
