Topical

OECD announces further guidance on the implementation of CbC Reporting

Posted on Updated on

Read the rest of this entry »

Advertisements

Eight Forum on Tax Administration (FTA) members start a multilateral TP and PE tax risk assurance programme

Posted on Updated on

Read the rest of this entry »

TP Back to Basics – Transfer Pricing Documentation

Posted on Updated on

This article is accompanied by a slide presentation on YouTube. Feel free to use my material for your own in-house purposes, all I ask is that you acknowledge the source. Read the rest of this entry »

BEPS Action 13: Jurisdictions implement final regulations for first filings of CbC Reports

Posted on

Source: OECD Press Release 21 December 2017

21/12/2017 – Today, a further important step was taken to implement Country-by-Country (CbC) Reporting in accordance with the BEPS Action 13 minimum standard, through activations of automatic exchange relationships under the Multilateral Competent Authority Agreement on the Exchange of CbC Reports (“the CbC MCAA”).

The automatic exchange of Country-by-Country Reports which is set to start in June 2018 will give tax administrations around the world access to key information on the annual income and profits, as well as the capital, employees and activities of Multinational Enterprise Groups that are active within their jurisdictions.

With more than six months before the first exchange deadline, there are now over 1400 automatic exchange relationships in place among jurisdictions committed to exchanging CbC Reports as of mid-2018, including those under EU Council Directive 2016/881/EU and bilateral competent authority agreements (including 31 with the United States).

OECD Press Release here

 

Facebook to overhaul Irish tax scheme

Posted on

Source: BBC.co.uk 12 December 2017

“Facebook is to overhaul its tax structure so that it pays tax in the country where profits are earned, instead of using an Irish subsidiary.

The online advertising giant is to make the change in every country outside the US where it has an office.

However, that does not necessarily mean it will start paying more tax in other countries as a result of the overhaul, Professor Prem Sikka of the universities of Sheffield and Essex told the BBC.

Taxes are paid on profits, and “the huge difficulty with large companies is trying to determine exactly what the profit is,” he said.

There are a number of ways firms can muddy the waters, including charging intra-group management fees, royalty fees, and profit-sharing, he said.”

source article here