Tax & Accounting Blog

Canada Publishes Form and Instructions for Country-by-Country Report

Canada Publishes Form and Instructions for Country-by-Country Report

On February 3, 2017, the Canada Revenue Agency (CRA) published a form (RC 4649) and instructions for completing the country-by-country (CbC) report for reporting fiscal years that begin after 2015. New section 233.8 of the Income Tax Act requires certain multinational enterprise (MNE) groups to file a CbC report. The report … Read More

Ireland Explains Time Limits on Revenue Opinions and Confirmations

Ireland Explains Time Limits on Revenue Opinions and Confirmations

On January 26, 2017, Irish Revenue (Revenue) published eBrief No. 08/17 regarding the period of validity of opinions and confirmations. Revenue will only provide an opinion or confirmation for complex issues, where information is not readily available or where there is genuine uncertainty regarding applicable tax rules. An opinion or confirmation represents Revenue’s … Read More

U.S. GAO Releases Report on BEPS Effects on U.S. Multinationals

U.S. GAO Releases Report on BEPS Effects on U.S. Multinationals

On January 27, 2017, the U.S. Government Accountability Office (GAO) published a draft report, Information on the Potential Impact on IRS and U.S. Multinationals of Revised International Guidance on Transfer Pricing (GAO-17-103), for the U.S. Internal Revenue Service (IRS) and Treasury, both of which have provided comments. In the report, the GAO analyzes … Read More

Chile Requires Taxpayers to Maintain Registry of Controlled Foreign Entities

Chile Requires Taxpayers to Maintain Registry of Controlled Foreign Entities

On January 20, 2017, the tax authority (Servicio de Impuestos Internos) published Resolution No. 9 (the “Resolution”), establishing the content and format of the registry that Chilean taxpayers, which directly or indirectly control entities located abroad (“controlled entities”), should maintain in accordance with article 41 G of the Income Tax Law … Read More

India Publishes Guidelines to Determine Company’s Place of Effective Management

India Publishes Guidelines to Determine Company’s Place of Effective Management

On January 24, 2017, India’s Ministry of Finance published Circular No. 6 of 2017, which provides guidelines for determining the place of effective management (“POEM”) of a company. See BEPS Action 6. Finance Act 2015 amended Section 6(3) of the Income Tax Act (“ITA”), effective from April … Read More