“OECD Forum on Tax Administration issues handbooks to address implementation and use of CbC reports”

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Source: Deloitte Global Transfer Pricing Alert 2017-044, 18 October 2017

This is a useful Deloitte summary of two recent OECD handbooks –

Country-by-Country Reporting: Handbook on Effective Implementation and

Country-by- Country Reporting: Handbook on Effective Tax Risk Assessment.

These handbooks are meant to assist tax authorities to use the information received through the exchange of country-by- country information within their tax risk assessment framework.


“Deadlines to Preserve Taxpayer Rights to Request Competent Authority Assistance to Relieve Double Taxation”

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Source: Deloitte (US) Global Transfer Pricing Alert 2017-045 18 October 2017

“Transfer pricing continues to be the top enforcement priority of tax authorities around the world, and one of the major risks for many multinationals. With foreign tax authorities aggressively asserting transfer pricing deficiencies, many taxpayers are receiving proposed adjustments regarding intercompany transactions. For this reason, it is imperative that taxpayers understand the actions required to preserve the right to request competent authority assistance to relieve double taxation.”

This informative Transfer Pricing Alert summarise the process for preserving Competent Authority assistance to relieve double taxation and lists the notification deadlines for US Treaty Partners.

Download a pdf copy of the Deloitte Tax Alert here


UK country-by-country reporting notification deadline approaches

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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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Leaked Deloitte Brexit memo “not commissioned by the Cabinet Office”

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Source: The Telegraph 15.11.2016

It is now known that the damaging memo, which was written on Nov 7 by Keith Leslie, a partner at Deloitte, had been intended for an “internal audience”. David Sproul, the chief executive of Deloitte UK, was a prominent Remain campaigner and signed a letter calling for the UK to remain in the EU.

Iain Duncan Smith, former work and pensions secretary, said that Deloitte should be stripped of Government contracts, “I don’t think this was an accident, this was quite deliberate. They were determined to do as much damage as possible.”

“This non-commissioned report is utterly bogus, gleaned from newspaper cuttings. The Government doesn’t need any more civil servants. What a load of old rubbish.”

After a day of criticism Deloitte released a statement admitting that the memo was “not commissioned by the Cabinet Office” and was “conducted without access to No 10 or input from other government departments”.

Source article here


Automation set to transform UK public services, according to a Deloitte Report

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Source: Deloitte press release 25 October 2016

Up to 861,000 public sector jobs – 16% of the overall workforce – could be automated by 2030 according to research by Deloitte.

The research builds on Deloitte’s work with Oxford University on job automation and is included in the firm’s The State of the State report – its annual analysis of the state of public finances and the challenges facing public services.

Mike Turley, global head of public sector at Deloitte, said: “In future, it will become even more important for the public sector to attract people with strong social and cognitive skills. A larger portion of the public sector will need to undertake complex, judgement-based problem solving and customer service as machines take over repetitive, administrative tasks.”

Deloitte press release here