Tax & Accounting Blog

OECD Releases Details of Country-by-Country Reporting Implementation and Exchange Relationships

OECD Releases Details of Country-by-Country Reporting Implementation and Exchange Relationships

On May 4, 2017, the OECD issued a press release on the implementation of country-by-country (CbC) reporting and corresponding automatic exchange agreements. Currently, 57 jurisdictions have signed the CbC Multilateral Competent Authority Agreement (CbC MCAA), which includes conditions to exchange CbC reports under the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. … Read More

Ireland Issues 2016 Annual Report, Includes Participation in BEPS Project

Ireland Issues 2016 Annual Report, Includes Participation in BEPS Project

On April 27, 2017, Irish Revenue issued its 2016 Annual Report, which discusses Ireland’s participation in the OECD BEPS project during that year. Ireland has joined the OECD Inclusive Framework for the global implementation of the BEPS project. As a member, Ireland has committed to implementing the four BEPS project minimum standards (Read More

Netherlands Advances Legislation to Substantially Increase Transfer Pricing Documentation Penalties

Netherlands Advances Legislation to Substantially Increase Transfer Pricing Documentation Penalties

On April 18, 2017, the Dutch lower house (House of Representatives) of Parliament adopted legislation (Bill No. 34651 and proposed Amendment No. 9) that would implement EU Directive 2016/881 (the “Directive) on automatic exchange of CbC reporting information among EU member states, and  increase the maximum documentation penalties. However, … Read More

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