Tax & Accounting Blog

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

Global Trade Trends: What Will Trump Mean for Trade?

Global Trade Trends: What Will Trump Mean for Trade?

Blog, Global Trade, ONESOURCE January 11, 2017

Words have consequences, and perhaps no words are more consequential than those of the president of the United States. The Nov. 8 election of Donald Trump, a populist whose campaign emphasized reversing the trade liberalization trend of recent decades, created instantaneous uncertainty for supply chains worldwide. Global trade liberalization will not grind to a halt … 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

License Exception SCP (Support for the Cuban People) – Where We Are Now?

License Exception SCP (Support for the Cuban People) – Where We Are Now?

From the time President Obama revealed his new foreign policy toward Cuba on December 17, 2014, the Bureau of Industry and Security (BIS), has issued six rules in the Federal Register that have established and increasingly liberalized the export license exception SCP, i.e., section 740.21 of the Export Administration Regulations (EAR).  While the most … Read More

U.S. IRS Updates List of International No-Ruling Areas

U.S. IRS Updates List of International No-Ruling Areas

On January 3, 2017, the U.S. Internal Revenue Service (IRS) issued Revenue Procedure ("Rev. Proc.") 2017-7, superseding Rev. Proc. 2016–7, providing a current list of areas of the Internal Revenue Code (the “Code”), under the jurisdiction of the Associate Chief Counsel (International), on which the IRS will not issue letter rulings … Read More

Chile Publishes Resolution Introducing Country-by-Country Reporting Requirement

Chile Publishes Resolution Introducing Country-by-Country Reporting Requirement

On December 27, 2016, the Chilean tax authorities (Servicio de Impuestos Internos – SII) published Resolution No. 126 (the “Resolution”). The Resolution updates the current annual transfer pricing return (affidavit) requirements to introduce an associated country-by-country (CbC) reporting requirement. See BEPS Action 13. The new CbC requirements include the following: Annual … Read More