Source: Deloitte Global Transfer Pricing Alert 2017-033
“The first country-by-country (CbC) reporting notifications required to be made to the UK tax authorities are due by 1 September 2017.
This deadline applies to all reporting periods that end on or before 1 September 2017.
After 1 September 2017, the standard UK notification date is the end of the CbC reporting period.
A few examples regarding the application of these rules follow.
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DRAFT REVISED GUIDANCE ON THE TRANSACTIONAL PROFIT SPLIT METHOD (TO REPLACE PART III SECTION C OF CHAPTER II OF THE 2010 TRANSFER PRICING GUIDELINES)
Source: OECD Discussion Draft, 22 June 2017. Deadline for responses – 15 September 2017
Public comments are invited on this discussion draft which deals with the clarification and strengthening of the guidance on the transactional profit split method, as set out in the BEPS Actions 8-10, 2015 Final Report.
This draft sets out the text of proposed revised guidance on the application of the transactional profit split method, together with a number of questions, listed below. Read the rest of this entry »
Country-By-Country Reporting (CBCR) is simply a report produced by multi-national enterprises (MNEs) showing their revenue, profit before tax, tax paid, tax accrued, capital, tangible earnings, retained earnings and their total number of employees, for each tax jurisdiction in which they operate. They are also required to identify each group member doing business in each jurisdiction along with details of their business activities.
OECD releases discussion draft on approaches to address BEPS involving interest in the banking and insurance sectors
28/07/2016 – Interested parties are invited 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.
Comments should be submitted by 8 September 2016 at the latest (no extension will be granted) by email to email@example.com in Word format. They should be addressed to the International Co-operation and Tax Administration Division, OECD/CTPA.
Please note that all comments received regarding this discussion draft will be made publicly available. Comments submitted in the name of a collective “grouping” or “coalition”, or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective grouping or coalition, or the person(s) on whose behalf the commentator(s) are acting.
The 2013 Organisation for Economic Co-operation and Development (OECD) Action Plan on Base Erosion and Profit Shifting (BEPS) recognised that existing internationally agreed rules for transfer pricing could be misapplied, resulting in outcomes where the allocation of profits is not aligned with the economic activity that produced those profits.
Of the fifteen Action Points in the BEPS Project, Actions 8 – 10 directly addressed transfer pricing and the arm’s length principle. Read the rest of this entry »