Tax & Accounting Blog

European Parliament Publishes Opinion on Legal Basis for Public Country-by-Country Reporting

European Parliament Publishes Opinion on Legal Basis for Public Country-by-Country Reporting

On January 17, 2017, the European Parliament’s Committee on Legal Affairs (the “Committee”) published its opinion on the appropriate legal basis for the disclosure of income tax information (i.e., public country-by-country (CbC) reporting). See BEPS Action 13. On January 12, 2017, the Committee decided that Article 50(1) of the Read More

Canada Publishes Form and Instructions for Country-by-Country Report

Canada Publishes Form and Instructions for Country-by-Country Report

On February 3, 2017, the Canada Revenue Agency (CRA) published a form (RC 4649) and instructions for completing the country-by-country (CbC) report for reporting fiscal years that begin after 2015. New section 233.8 of the Income Tax Act requires certain multinational enterprise (MNE) groups to file a CbC report. The report … Read More

Ireland Explains Time Limits on Revenue Opinions and Confirmations

Ireland Explains Time Limits on Revenue Opinions and Confirmations

On January 26, 2017, Irish Revenue (Revenue) published eBrief No. 08/17 regarding the period of validity of opinions and confirmations. Revenue will only provide an opinion or confirmation for complex issues, where information is not readily available or where there is genuine uncertainty regarding applicable tax rules. An opinion or confirmation represents Revenue’s … Read More

U.S. GAO Releases Report on BEPS Effects on U.S. Multinationals

U.S. GAO Releases Report on BEPS Effects on U.S. Multinationals

On January 27, 2017, the U.S. Government Accountability Office (GAO) published a draft report, Information on the Potential Impact on IRS and U.S. Multinationals of Revised International Guidance on Transfer Pricing (GAO-17-103), for the U.S. Internal Revenue Service (IRS) and Treasury, both of which have provided comments. In the report, the GAO analyzes … Read More

Chile Requires Taxpayers to Maintain Registry of Controlled Foreign Entities

Chile Requires Taxpayers to Maintain Registry of Controlled Foreign Entities

On January 20, 2017, the tax authority (Servicio de Impuestos Internos) published Resolution No. 9 (the “Resolution”), establishing the content and format of the registry that Chilean taxpayers, which directly or indirectly control entities located abroad (“controlled entities”), should maintain in accordance with article 41 G of the Income Tax Law … Read More