Tax & Accounting Blog

Reflecting on BEPS Regulations and Country-by-Country Reporting at TP Minds Americas

Reflecting on BEPS Regulations and Country-by-Country Reporting at TP Minds Americas

I have recently returned from the TP Minds Americas Transfer Pricing Summit in beautiful Miami, Florida where I had the privilege of presenting a session on entitled: “New BEPS Regulations and Country-by-Country Reporting: Practical Steps To Compliance.” I was fortunate to be joined by Sharon Rosiak, International Tax Manager and BEPS Action Plans Implementation … Read More

Russian Amendments to Controlled Foreign Corporation and Thin Capitalization Rules Enter into Force

Russian Amendments to Controlled Foreign Corporation and Thin Capitalization Rules Enter into Force

On February 15, 2016, Russian President Vladimir Putin signed Federal Law N 32-FZ (amending Chapter 3.4. of the Russian Tax Code (Tax Code) with regard to controlled foreign corporations (CFCs)) and Federal Law N 25-FZ, which revises existing thin capitalization rules (Article 269 of the Tax Code). We will address each … Read More

U.S. FY2017 Budget Includes BEPS-Related Proposals

U.S. FY2017 Budget Includes BEPS-Related Proposals

On February 9, 2016, President Obama submitted the Administration’s FY 2017 budget proposals to Congress. The budget included a number of international tax proposals that are similar to the FY 2016 proposals, specifically related to BEPS, including the following: Restrict deductions for excessive interest of members of financial reporting groups Limit shifting of income … Read More

Denmark Updates Tax Guide Addressing Certain BEPS Provisions

Denmark Updates Tax Guide Addressing Certain BEPS Provisions

On January 29, 2016, the Danish tax authorities (SKAT) issued Legal Guidance 2016-1, which provides background information on Denmark’s tax system and its application, including its Controlled Foreign Company (CFC) rules  (OECD BEPS Action 3), transfer pricing rules (BEPS Actions 8-10), and transfer pricing documentation rules (OECD BEPS Action … Read More

Belgium Publishes Plan to Address BEPS and Combat Tax Fraud

Belgium Publishes Plan to Address BEPS and Combat Tax Fraud

On December 3, 2015, the Belgian Minister of Finance published a policy note entitled the Plan to Combat the Tax Fraud (the Plan), which addresses Belgium’s potential implementation of the OECD BEPS Project recommendations issued on October 5, 2015. The goal of the Plan is to have coordinated, as opposed to unilateral, … Read More

South Africa on Track to Implement Country-by-Country Reporting

South Africa on Track to Implement Country-by-Country Reporting

On December 23, 2014, South Africa’s Davis Tax Committee (“DTC”) released a First Interim Report on BEPS (the Report) for public comment. The DTC was formed by the Minister of Finance on July 17, 2013 to “evaluate the South African tax system against the international tax trends, principles and practices, as well as recent … Read More