Tax & Accounting Blog

French National Assembly Approves Diverted Profits Tax Proposals

French National Assembly Approves Diverted Profits Tax Proposals

According to the French National Assembly (the “Assembly”), many companies artificially divert profits from activities performed in France by avoiding the establishment of a taxable presence in France and by taking advantage of loopholes in tax legislation. As a result, on November 7, 2016, the Assembly approved Amendment No. II-CF421 (the “Amendment”) to … Read More

Finland Proposes to Extend 2016 CbC Reporting Notification Deadline

Finland Proposes to Extend 2016 CbC Reporting Notification Deadline

On September 15, 2016, Finland submitted its 2017 budget proposals (HE 142/2016) to Parliament for consideration, which would introduce CbC reporting, master file, and local file requirements starting with fiscal years that begin on or after January 1, 2016. The CbC reporting requirements (new Sections 14(d) and (e) of the Tax Assessment Procedure … Read More

Section 385 Final Regs. Modify Prop. Regs. to “Minimize Burdens” on Taxpayers

Section 385 Final Regs. Modify Prop. Regs. to “Minimize Burdens” on Taxpayers

In 518-page TD 9790 , October 13, 2016, IRS issued final and Temporary Regulations ("final Regulations") under Section 385 that (1) establish threshold documentation requirements that ordinarily must be satisfied so that certain related-party interests in a corporation are treated as indebtedness for federal tax purposes; and (2) treat certain other … Read More

France Publishes Legislation Proposing to Introduce Public Country-by-Country Reporting

France Publishes Legislation Proposing to Introduce Public Country-by-Country Reporting

On November 8, 2016, France published the transparency and anti-corruption bill (Law No. 830). See also corresponding Explanatory Report. A key measure included in the bill is the proposed adoption of public country-by-country (CbC) reporting. See BEPS Action 13. Companies that prepare consolidated accounts with turnover of at least … Read More

Germany Implements Automatic Exchange of CbC Reporting Information

Germany Implements Automatic Exchange of CbC Reporting Information

While Germany has not yet adopted the country-by-country (CbC) reporting proposals that the Ministry of Finance (MOF) sent to Parliament for consideration on July 13, 2016, on October 25, 2016, Germany published legislation in the official gazette that  the MOF issued on April 12, 2016.  The legislation implements the OECD Multilateral … Read More