Tax & Accounting Blog

French National Assembly Approves Diverted Profits Tax Proposals

French National Assembly Approves Diverted Profits Tax Proposals

According to the French National Assembly (the “Assembly”), many companies artificially divert profits from activities performed in France by avoiding the establishment of a taxable presence in France and by taking advantage of loopholes in tax legislation. As a result, on November 7, 2016, the Assembly approved Amendment No. II-CF421 (the “Amendment”) to … Read More

Finland Proposes to Extend 2016 CbC Reporting Notification Deadline

Finland Proposes to Extend 2016 CbC Reporting Notification Deadline

On September 15, 2016, Finland submitted its 2017 budget proposals (HE 142/2016) to Parliament for consideration, which would introduce CbC reporting, master file, and local file requirements starting with fiscal years that begin on or after January 1, 2016. The CbC reporting requirements (new Sections 14(d) and (e) of the Tax Assessment Procedure … Read More

France Publishes Legislation Proposing to Introduce Public Country-by-Country Reporting

France Publishes Legislation Proposing to Introduce Public Country-by-Country Reporting

On November 8, 2016, France published the transparency and anti-corruption bill (Law No. 830). See also corresponding Explanatory Report. A key measure included in the bill is the proposed adoption of public country-by-country (CbC) reporting. See BEPS Action 13. Companies that prepare consolidated accounts with turnover of at least … Read More

Germany Implements Automatic Exchange of CbC Reporting Information

Germany Implements Automatic Exchange of CbC Reporting Information

While Germany has not yet adopted the country-by-country (CbC) reporting proposals that the Ministry of Finance (MOF) sent to Parliament for consideration on July 13, 2016, on October 25, 2016, Germany published legislation in the official gazette that  the MOF issued on April 12, 2016.  The legislation implements the OECD Multilateral … Read More

South Africa Increases Transfer Pricing Documentation Requirements

South Africa Increases Transfer Pricing Documentation Requirements

On October 28, 2016, the South Africa Revenue Service (SARS) issued Notice No. 1334 concerning additional transfer pricing documentation requirements, under Section 29 of the Tax Administration Act, for South African companies with cross-border related-party transactions that exceed R 100 million each year in the aggregate. If the threshold is met, the additional … Read More

Brazil Publishes Consultation on Implementation of Country-by-Country Reporting

Brazil Publishes Consultation on Implementation of Country-by-Country Reporting

On November 7, 2016, Brazil’s Ministry of Finance and the Brazilian IRS published Public Consultation RFB No.11/2016 to implement annual country-by-country (CbC) reporting in Brazil. See BEPS Action 13. The consultation runs from November 7 to November 21, 2016. The consultation says that if Brazil does not implement CbC reporting, then … Read More