Tax & Accounting Blog

Poland Requires Annual Update of Financial Transaction Information in Transfer Pricing Documentation

Poland Requires Annual Update of Financial Transaction Information in Transfer Pricing Documentation

On April 3, 2018, Poland’s Ministry of Finance issued General Interpretation No. DCT.8201.6.2018 of March 28, 2018 regarding updates to  transfer pricing documentation (TPD). Pursuant to Article 9(a)(2)(g) of the Corporate Income Tax Act (CIT), Polish taxpayers must update their TPD each year to account for financial … Read More

BDO’s Joseph Calianno on Companies’ Response to the TCJA

BDO’s Joseph Calianno on Companies’ Response to the TCJA

Joe Calianno is a Tax Partner and serves as BDO’s International Technical Tax Practice Leader. He also is a former Special Counsel to the Deputy Associate Chief Counsel (International) in the office of Chief Counsel for the Internal Revenue Service (IRS). Additionally, Mr. Calianno is a member of the AICPA’s Tax Executive Committee, and previously … Read More

South Korea Issues Enforcement Decree and Guidance on 2018 Tax Reform Measures

South Korea Issues Enforcement Decree and Guidance on 2018 Tax Reform Measures

On February 13, 2018, South Korea’s Ministry of Strategy and Finance (MOSF) issued an Enforcement Decree to provide guidance on the 2018 tax reform legislation, enacted on December 19, 2017, which includes the BEPS Action 2, 4, and 13 measures discussed below. Hybrid Mismatch Rules (BEPS Action 2) Hybrid mismatch arrangements exploit differences in … Read More

Sweden Proposes New Rules on Interest Deductibility and Hybrid Mismatches

Sweden Proposes New Rules on Interest Deductibility and Hybrid Mismatches

On March 21, 2018, Sweden’s  Ministry of Finance issued draft legislation to amend Sweden’s corporate tax rules, including to implement anti-hybrid mismatch and interest expense limitation rules based on the EU Anti-Tax Avoidance Directive (ATAD 1) issued on July 12, 2016, and the May 19, 2017, amendments … Read More