Tax & Accounting Blog

OECD Releases 2017 Edition of Transfer Pricing Guidelines

OECD Releases 2017 Edition of Transfer Pricing Guidelines

On July 10, 2017, the OECD released its 2017 version of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“TP Guidelines”), which provide guidance on the application of the arm’s length principle.  The TP Guidelines define the “arm’s length principle” as “the international standard that OECD member countries have agreed … Read More

European Parliament Supports Proposal to Disclose Country-by-Country Information

European Parliament Supports Proposal to Disclose Country-by-Country Information

On July 4, 2017, the European Parliament (EP), in a plenary session, adopted amendments on the proposal for a directive to amend EU Directive 2013/34 regarding the disclosure of income tax information by certain undertakings and branches. See the accompanying press release. The EP approved the draft report on the proposal by … Read More

BEPS, MLI software, effect of U.S. not signing MLI, tax transparency, updated Transfer Pricing Guidelines: latest from OECD

BEPS, MLI software, effect of U.S. not signing MLI, tax transparency, updated Transfer Pricing Guidelines: latest from OECD

The OECD’s latest Tax Talks webcast held on June 26, 2017 covered the latest developments on the international tax agenda, including BEPS and tax transparency. On BEPS in general, Pascal Saint-Amans, Director, OECD Centre for Tax Policy and Administration, said that more than 95% of the world’s economy had committed to, and was implementing, BEPS measures. … Read More

U.S. IRS Signs More Competent Authority Agreements on Exchange of CbC Reports

U.S. IRS Signs More Competent Authority Agreements on Exchange of CbC Reports

As of June 26, 2017, the IRS has signed bilateral competent authority agreements (CAAs) on the exchange of country-by-country (CbC) reports with the following jurisdictions: Canada – signed on June 7, 2017; CAA not yet available. Denmark – signed on June 21, 2017; CAA not yet available. Guernsey – signed on June 22, 2017; CAA … Read More

Brazil Updates FAQs on Country-by-Country Reporting Requirements

Brazil Updates FAQs on Country-by-Country Reporting Requirements

On June 9, 2017, Brazil issued updated FAQs on country-by-country (CbC) reporting. On December 29, 2016, Brazil published Normative Instruction No. 1681/2016, requiring CbC reporting for fiscal years that begin on or after January 1, 2016. See BEPS Action 13. The FAQs address the following considerations (among others): Whether extraordinary revenues and gains from … Read More