Tax & Accounting Blog

BEPS and Other Notable Int’l Measures in Draft Senate GOP Tax Reform Plan

BEPS and Other Notable Int’l Measures in Draft Senate GOP Tax Reform Plan

The release of major tax reform legislation in the U.S. is generating great interest around the world. The proposal to cut the U.S. corporate tax rate significantly, and the potentially dramatic effect on international taxation generally, make the legislation that much more important. On November 9, 2017, the U.S. Senate Finance Committee (the “Committee”) released … Read More

BEPS and Other Notable Int’l Measures in Final U.S. House GOP Tax Reform Bill

BEPS and Other Notable Int’l Measures in Final U.S. House GOP Tax Reform Bill

The release of major tax reform legislation in the U.S. is generating great interest around the world. The proposal to cut the U.S. corporate tax rate significantly, and the potentially dramatic effect on international taxation generally, make the legislation that much more important. On November 2, 2017, the Republican members of the U.S. House of … Read More

Belgium Implements Anti-Tax Avoidance Measures

Belgium Implements Anti-Tax Avoidance Measures

On October 27, 2017, Belgium issued an overview of tax reform proposals, several of which implement EU Directive 2016/1164 of July 12, 2016 (ATAD 1) (the “Directive”) regarding hybrid mismatches, controlled foreign companies (CFCs) and limitation on interest deductions. On October 27, 2017, the Belgian Ministry of Finance also announced … Read More

Mexico Announces Release of Online Platform and Forms for Filing Transfer Pricing Documentation

Mexico Announces Release of Online Platform and Forms for Filing Transfer Pricing Documentation

On October 31, 2017, the Mexican tax authority (Servico de Administracion Tributaria or SAT) announced that its online platform and electronic forms will be ready starting on November 1, 2017, for taxpayers to file their new transfer pricing documentation (i.e., country-by-country (CbC) report, master file, and local file). Editor’s Note: This means that there … Read More

Corrected: U.S. May Not Finalize All CbCR Exchange Agreements by 2017 Deadline

Corrected: U.S. May Not Finalize All CbCR Exchange Agreements by 2017 Deadline

On October 27, 2017, a U.S. Internal Revenue Service (IRS) Large Business and International (LB&I) official, Theodore Setzer (Assistant Deputy Commissioner – International), said during an ABA Tax Section conference in Washington, D.C. that the IRS may not be able to sign some bilateral competent authority agreements (CAAs) in 2017 with its treaty partners … Read More

India Issues Final Rules on Master File and Country-by-Country Report Requirements

India Issues Final Rules on Master File and Country-by-Country Report Requirements

On November 1, 2017, the Indian Ministry of Finance issued a press release on the Central Board of Direct Taxes (CBDT) rules regarding transfer pricing documentation (TPD) in the master file and country-by-country (CbC) report. India has implemented the OECD BEPS Action 13 recommendations on TPD and CbC reporting by adding section … Read More