Tax & Accounting Blog

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

Finland Issues Guidance on Country-by-Country Reporting

Finland Issues Guidance on Country-by-Country Reporting

On December 21, 2016, the Finnish Tax Administration (VERO) issued Draft Guidance A240/200/2016 on country-by-country (CbC) reporting requirements ("Guidance"), the provisions of which entered into force on January 1, 2017. The Guidance provides information on CbC reporting requirements and deadlines, and is aligned with the OECD BEPS Action 13 final report. The first … Read More

U.S. IRS Releases Information on Early Filing of Form 8975 and Schedule A

U.S. IRS Releases Information on Early Filing of Form 8975 and Schedule A

On January 19, 2017, the U.S. Internal Revenue Service (IRS) released Revenue Procedure 2017-23, which describes the process for filing Form 8975, Country-by-Country Report, and accompanying Schedule A, Tax Jurisdiction and Constituent Entity Information (collectively, Form 8975), by ultimate parent entities of U.S. multinational enterprise (MNE) groups for reporting … Read More

Indonesia Implements Three-Tiered Transfer Pricing Documentation Requirements

Indonesia Implements Three-Tiered Transfer Pricing Documentation Requirements

On December 30, 2016, the Indonesian Minister of Finance published PMK213/ PMK.03 / 2016, which provides details on the three-tiered transfer pricing documentation requirements (master file, local file and country-by-country (CbC) report) for related party transactions in accordance with BEPS Action 13. The master file must include the following information about … Read More

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