Tax & Accounting Blog

Netherlands Addresses Parliament Concerns over Tax Rulings

Netherlands Addresses Parliament Concerns over Tax Rulings

On April 14, 2017, the Dutch Finance Secretary wrote a letter to Parliament, the Annex of which addresses Parliament’s questions and concerns over the Netherlands advance pricing agreement (APA) / advance tax ruling (ATR) practice (the “Rulings”). On December 29, 2016, the Netherlands published the Law of December 21, … Read More

India Introduces Interest Deduction Limitation Rules in Finance Act 2017

India Introduces Interest Deduction Limitation Rules in Finance Act 2017

On March 31, 2017, India enacted Finance Act 2017, which introduces measures in Clause 43 to limit interest expense deductions on related-party debts to 30% of the debtors (Indian company or an Indian permanent establishment (PE) of a foreign company) earnings before interest, taxes, depreciation, and amortization (EBITDA), or 30% of interest paid … Read More

Mexico Publishes Modifications to Transfer Pricing Documentation Requirements

Mexico Publishes Modifications to Transfer Pricing Documentation Requirements

On April 3, 2017, Mexico’s Office of the Taxpayer Advocate (PRODECON) published a final report for presenting the master file, local file and country-by-country (CbC) report under Article 76-A of the Income Tax Law. These documentation requirements apply from January 1, 2016, with initial CbC reports due by December 31, 2017 … Read More

The Netherlands Issues Proposed Beneficial Ownership Register Legislation

The Netherlands Issues Proposed Beneficial Ownership Register Legislation

On March 31, 2017, the Dutch Ministry of Finance issued a public consultation (and explanatory report) on draft legislation that would introduce a beneficial ownership register (registratie uiteindelijk belanghebbenden) in the Trade Register Act 2007 via the Fourth EU Anti-Money Laundering Directive (2015/849) (the "Directive" or AMLD4) of May 20, 2015. … Read More