Tax & Accounting Blog

UK’s DPT Challenge to Glencore – Can One Defend 80 Percent of the Profits for 20 Percent of the Functions?

UK’s DPT Challenge to Glencore – Can One Defend 80 Percent of the Profits for 20 Percent of the Functions?

Saumyanil Deb and I noted that the UK Diverted Profits Tax should allow taxpayers a chance to defend its intercompany pricing based on a reasonable model of the intercompany transaction in question. In an earlier paper, I posed a simple model of the appropriate gross margin for a sales affiliate, which we applied to the … Read More

Greece Implements EU Rules on Exchange of Country-by-Country Reports

Greece Implements EU Rules on Exchange of Country-by-Country Reports

On August 1, 2017, Greece published Law No. 4484 (the “Law”) in the Government newspaper, The Hellenic Democracy. The Law implements EU Directive 2016/881 (amending Directive 2011/16, which was previously amended by Directives 2014/107 and 2015/2376) on the mandatory automatic exchange of tax information (e.g., country-by-country (CbC) reports) into domestic legislation. See Read More

U.S. Treasury and Internal Revenue Service Delay Application of Documentation Regulations under Section 385

U.S. Treasury and Internal Revenue Service Delay Application of Documentation Regulations under Section 385

U.S. Internal Revenue Code (IRC) section 385 authorizes the Secretary of the Treasury to prescribe rules to determine whether an interest in a corporation is treated for purposes of the IRC as stock or indebtedness (or as in part stock and in part indebtedness) by providing factors to be taken into account with respect … Read More