Tax & Accounting Blog

France Ratifies Multilateral Agreement to Automatically Exchange CbC Reports

France Ratifies Multilateral Agreement to Automatically Exchange CbC Reports

On April 28, 2017, France issued Decree No. 2017-672, ratifying the OECD Multilateral Competent Authority Agreement for the Automatic Exchange of CbC reports (“CbC MCAA”), which was signed in Paris on January 27, 2016. On October 1, 2016, France implemented the CbC reporting requirements introduced in the 2016 Finance Act, which … Read More

Ireland Issues 2016 Annual Report, Includes Participation in BEPS Project

Ireland Issues 2016 Annual Report, Includes Participation in BEPS Project

On April 27, 2017, Irish Revenue issued its 2016 Annual Report, which discusses Ireland’s participation in the OECD BEPS project during that year. Ireland has joined the OECD Inclusive Framework for the global implementation of the BEPS project. As a member, Ireland has committed to implementing the four BEPS project minimum standards (Read More

U.S. Publishes Model Competent Authority Arrangements on Exchange of Country-by-Country (CbC) Reports

U.S. Publishes Model Competent Authority Arrangements on Exchange of Country-by-Country (CbC) Reports

On April 6, 2017, the U.S. Internal Revenue Service (IRS) published two model competent authority arrangements (CAAs) for the exchange of country-by-country (CbC) reports. One CAA is based on a double tax convention (DTC) and the other arrangement is based on a tax information exchange agreement (TIEA). See BEPS Action 13. Under Article [26] … Read More

Netherlands Addresses Parliament Concerns over Tax Rulings

Netherlands Addresses Parliament Concerns over Tax Rulings

On April 14, 2017, the Dutch Finance Secretary wrote a letter to Parliament, the Annex of which addresses Parliament’s questions and concerns over the Netherlands advance pricing agreement (APA) / advance tax ruling (ATR) practice (the “Rulings”). On December 29, 2016, the Netherlands published the Law of December 21, … Read More

India Introduces Interest Deduction Limitation Rules in Finance Act 2017

India Introduces Interest Deduction Limitation Rules in Finance Act 2017

On March 31, 2017, India enacted Finance Act 2017, which introduces measures in Clause 43 to limit interest expense deductions on related-party debts to 30% of the debtors (Indian company or an Indian permanent establishment (PE) of a foreign company) earnings before interest, taxes, depreciation, and amortization (EBITDA), or 30% of interest paid … Read More