Tax & Accounting Blog

U.S. Publishes Model Competent Authority Arrangements on Exchange of Country-by-Country (CbC) Reports

U.S. Publishes Model Competent Authority Arrangements on Exchange of Country-by-Country (CbC) Reports

On April 6, 2017, the U.S. Internal Revenue Service (IRS) published two model competent authority arrangements (CAAs) for the exchange of country-by-country (CbC) reports. One CAA is based on a double tax convention (DTC) and the other arrangement is based on a tax information exchange agreement (TIEA). See BEPS Action 13. Under Article [26] … Read More

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

What It Means to Japan Now That the U.S. Is No Longer Participating In the TPP

What It Means to Japan Now That the U.S. Is No Longer Participating In the TPP

The official announcement, January 20, 2017, from the U.S. President regarding separation as a member of the Trans Pacific Partnership Agreement (TPP) was an unexpected outcome for most industries in Japan.  Japan had much to gain with the U.S. on this agreement and had been looking to establish new processes and procedures based on the … Read More