Tax & Accounting Blog

Canada Announces BEPS Measures in 2016 Federal Budget

Canada Announces BEPS Measures in 2016 Federal Budget

On March 22, 2016, Canada’s new Liberal Party-run government issued its 2016 Federal Budget (the “Budget”) before Parliament. The Budget includes several international tax proposals, and for the first time, addresses whether the government intends to implement the OECD BEPS Project recommendations. Aside from treaty dispute resolution mechanisms (BEPS Action 14), the Read More

Turkey Issues Draft Communiqué on Transfer Pricing Documentation

Turkey Issues Draft Communiqué on Transfer Pricing Documentation

On March 16, 2016, the Turkish Revenue Administration issued draft General Communiqué No. 3 (the “Communiqué”) that, once finalized, would expand certain legal requirements and would introduce new transfer pricing documentation rules that generally follow the BEPS Action 13 recommendations, and provide for country-by-country reporting (CbCR). The Communiqué introduces additional transfer pricing … Read More

U.K. Issues Final CbC Reporting Regulations

U.K. Issues Final CbC Reporting Regulations

On February 26, 2016, the government submitted the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016 before Parliament, which will enter into force on March 18, 2016. The final regulations follow the public technical consultation that ran through November 16, 2015, on the proposed country-by-country (CbC) reporting regulations that HMRC issued on … Read More

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