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Countries agree on BEPS measures for country-by-country reporting, IP regimes, multilateral instrument

February 6, 2015

OECD and G20 countries have agreed to a framework for country-by-country reporting by multinational corporations, to the criteria to assess whether preferential intellectual property regimes are harmful, and to a plan to create a multilateral instrument to implement tax treaty-related measures, the OECD said February 6. The agreements, which implement OECD/G20 base erosion profit shifting (BEPS) plan, will be . . .

UPDATE (2/10/2015): G20 finance ministers endorse plan for multilateral instrument: G20 finance ministers have agreed to a mandate to create a multilateral instrument to implement tax treaty-related measures under OECD/G20 the base erosion and profit shifting (BEPS) plan, the ministers said in a communique following their February 9-10 meeting in Istanbul . . .

Europe

Journalists publish leaked advance rulings and tax returns, conclude that Luxembourg aids tax avoidance

November 6, 2014

The International Consortium of Investigative Journalists (ICIJ)  on November 5 published confidential tax documents of PwC clients on the Internet accompanied by a series of news stories that conclude that Luxembourg has been a long-time partner in multinational corporation tax avoidance. The leaked documents include 548 Luxembourg advance rulings, or comfort letters; corporate tax returns . . .

Luxembourg defends tax rulings: “The rulings in Luxembourg are compatible with the Luxembourg legislation, compatible with the EU-legislation, and compatible with the OECD-conventions, and any other international conventions,” Minister of Finance, Pierre Gramegna, said November 6, at the Ecofin council in Brussels. See speech.

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Jean-Claude Juncker should resign says Bloomberg: Jean-Claude Juncker, the new president of the European Commission, has a “clear conflict of interest” as head of the body investigating the tax practices he oversaw as Luxembourg’s prime minister, says Bloomberg in a November 9 opinion piece. See, Bloomberg.

Europe

EU Commission recommends public release of country-by-country reporting for banks

October 30, 2014

The European Commission has concluded that public dissemination of country-by-country reporting by banks will not have a negative impact on the economy, paving the way for public release of the data by January 1, 2015.  “At this stage, the public country-by-country reporting of information under Article 89 of Directive 2013/36/EU is not expected to have significant negative economic impact, in particular on competitiveness, investment, . . .

Europe

Netherlands updates guidance on advance tax rulings, APAs, and substance requirements

June 19, 2014

The Netherlands Ministry of Finance, on June 12, published five decrees updating guidance on advance pricing agreements (APAs), advance tax rulings (ATRs), and minimum substance requirements to obtain an APA or ATR, according to a report by Loyens & Loeff. Minimum substance requirements are also provided for service companies that do not have an APA that wish to apply the Dutch treaty network or the EU Interest & Royalty Directive. For details and analysis, see a June 12 report by Loyens & Loeff

Europe

Ireland regains its swagger in the tax arena

December 14, 2015

Aisling Donohue, a tax partner with mgpartners, Dublin, discusses Ireland’s unexpectedly large 2015 corporation tax receipts and the country’s likely response to the OECD/20 base erosion profit shifting (BEPS) recommendations and the EU proposals for a common consolidated corporate tax base (CCCTB) and a financial transactions tax.

Americas

Jeb Bush tax plan calls for territorial tax system, deemed repatriation of existing overseas profits

September 9, 2015

US presidential candidate Jeb Bush unveiled his tax plan in The Wall Street Journal on September 8, proposing a 20 percent corporate tax rate, limits on tax deductions, and a move to a territorial tax system coupled with “a one-time tax of 8.75%, payable over 10 years, on the more than $2 trillion in corporate profits sitting overseas.” See: The Wall Street Journal.