Tax & Accounting Blog

Ireland Issues FAQs on Qualifying Disclosure for “Offshore Matters”

Ireland Issues FAQs on Qualifying Disclosure for “Offshore Matters”

On January 9, 2017, Ireland issued FAQs on qualifying disclosures relating to offshore matters.  See BEPS Action 12. Ireland has proposed measures in section 54 of the Finance Bill 2016 to address offshore tax evasion in light of the new international measures for exchange of information. If enacted, the proposed legislation … Read More

Austria Publishes Ordinance on Master and Local File Documentation Requirements

Austria Publishes Ordinance on Master and Local File Documentation Requirements

On December 21, 2016, Austria published an Ordinance on transfer pricing documentation in the official gazette, clarifying the requirements for the master and local files, which will apply to years beginning January 1, 2016. See BEPS Action 13. Master File The master file must include the following: Organizational structure of the … Read More

U.S. IRS Updates List of International No-Ruling Areas

U.S. IRS Updates List of International No-Ruling Areas

On January 3, 2017, the U.S. Internal Revenue Service (IRS) issued Revenue Procedure ("Rev. Proc.") 2017-7, superseding Rev. Proc. 2016–7, providing a current list of areas of the Internal Revenue Code (the “Code”), under the jurisdiction of the Associate Chief Counsel (International), on which the IRS will not issue letter rulings … Read More

Chile Publishes Resolution Introducing Country-by-Country Reporting Requirement

Chile Publishes Resolution Introducing Country-by-Country Reporting Requirement

On December 27, 2016, the Chilean tax authorities (Servicio de Impuestos Internos – SII) published Resolution No. 126 (the “Resolution”). The Resolution updates the current annual transfer pricing return (affidavit) requirements to introduce an associated country-by-country (CbC) reporting requirement. See BEPS Action 13. The new CbC requirements include the following: Annual … Read More

Brazil Publishes Country-by-Country Reporting Requirements

Brazil Publishes Country-by-Country Reporting Requirements

On December 29, 2016, Brazil published Normative Instruction RFB No. 1681, requiring country-by-country (CbC) reporting. See BEPS Action 13. The ultimate parent entity, or another entity that is a Brazilian tax resident, is required to submit the CbC report. An entity other than the ultimate parent can submit the report if … Read More

Luxembourg Publishes Extended Notifications for Country-by-Country Reporting

Luxembourg Publishes Extended Notifications for Country-by-Country Reporting

On December 27, 2016, Luxembourg published a newsletter, saying that the government has implemented country-by-country (CbC) reporting and the mandatory automatic exchange of CbC information. See BEPS Action 13. On December 13, 2016, the Luxembourg Parliament adopted Law No. 7031, implementing CbC reporting and the mandatory automatic exchange of … Read More