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In the past month, I’ve received several phone calls from previous clients asking about Authorized Economic Operator (AEO) re-certification. It seems these high level AEO enterprises are facing challenges and do not have a clear understanding of all the local AEO requirements. Failing to pass AEO certification would mean a potential loss of preferential benefits. … Read More
On June 15, 2017, U.K. HMRC issued updated guidance on the Worldwide Disclosure Facility (WDF). See BEPS Action 12. On December 31, 2015, all HMRC offshore facilities closed. The WDF is currently available to anyone who would like to disclose a U.K. tax liability that relates wholly or partly to an offshore issue, … Read More
The OECD’s latest Tax Talks webcast held on June 26, 2017 covered the latest developments on the international tax agenda, including BEPS and tax transparency. On BEPS in general, Pascal Saint-Amans, Director, OECD Centre for Tax Policy and Administration, said that more than 95% of the world’s economy had committed to, and was implementing, BEPS measures. … Read More
As of June 26, 2017, the IRS has signed bilateral competent authority agreements (CAAs) on the exchange of country-by-country (CbC) reports with the following jurisdictions: Canada – signed on June 7, 2017; CAA not yet available. Denmark – signed on June 21, 2017; CAA not yet available. Guernsey – signed on June 22, 2017; CAA … Read More
On June 9, 2017, Brazil issued updated FAQs on country-by-country (CbC) reporting. On December 29, 2016, Brazil published Normative Instruction No. 1681/2016, requiring CbC reporting for fiscal years that begin on or after January 1, 2016. See BEPS Action 13. The FAQs address the following considerations (among others): Whether extraordinary revenues and gains from … Read More
On May 25, 2017, Brazil published RFB Normative Instruction No. 1,709/2017 in the official gazette to amend certain parts of the country-by-country (CbC) reporting rules in Normative Instruction No. 1,681/2016 (issued on December 29, 2016). Brazil introduced CbC reporting via Normative Instruction No. 1,681/2016 for fiscal years that begin on or after … Read More