Tax & Accounting Blog

Foreign Trade in the 21st Century

Foreign Trade in the 21st Century

There have been numerous activities related to political changes, technological progress and globalization that have undergone extreme radical transformations since the second half of the 20th century. Foreign Trade has not escaped these transformations causing an accelerated growth that is changing the way countries and companies trade with extraordinary speed. Today, there is not a … 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

Is Everything Negotiable in Trade?

Is Everything Negotiable in Trade?

In January 2017, I wrote an article shortly after the Trump Administration took office discussing their official withdrawal from the Trans-Pacific Partnership (TPP). This answered my own rhetorical question of whether the U.S. withdrawal effectively killed all new multilateral agreements with the response, “it depends on who you ask.”[1]  Since then, many (including … 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