Tax & Accounting Blog

IRS Currently Accepting Form 8975, Country-by-Country Report

IRS Currently Accepting Form 8975, Country-by-Country Report

On August 11, 2017, the U.S. Internal Revenue Service (IRS) issued Bulletin 2017-2 on its acceptance of Form 8975, Country-by-Country Report. Ultimate parent entities (UPEs) of U.S. multinational enterprise (MNE) groups with $850 million or more of revenues in a previous annual reporting period can now file Read More

UK’s DPT Challenge to Glencore – Can One Defend 80 Percent of the Profits for 20 Percent of the Functions?

UK’s DPT Challenge to Glencore – Can One Defend 80 Percent of the Profits for 20 Percent of the Functions?

Saumyanil Deb and I noted that the UK Diverted Profits Tax should allow taxpayers a chance to defend its intercompany pricing based on a reasonable model of the intercompany transaction in question. In an earlier paper, I posed a simple model of the appropriate gross margin for a sales affiliate, which we applied to the … Read More

Greece Implements EU Rules on Exchange of Country-by-Country Reports

Greece Implements EU Rules on Exchange of Country-by-Country Reports

On August 1, 2017, Greece published Law No. 4484 (the “Law”) in the Government newspaper, The Hellenic Democracy. The Law implements EU Directive 2016/881 (amending Directive 2011/16, which was previously amended by Directives 2014/107 and 2015/2376) on the mandatory automatic exchange of tax information (e.g., country-by-country (CbC) reports) into domestic legislation. See Read More