Tax & Accounting Blog

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

India Publishes Guidelines to Determine Company’s Place of Effective Management

India Publishes Guidelines to Determine Company’s Place of Effective Management

On January 24, 2017, India’s Ministry of Finance published Circular No. 6 of 2017, which provides guidelines for determining the place of effective management (“POEM”) of a company. See BEPS Action 6. Finance Act 2015 amended Section 6(3) of the Income Tax Act (“ITA”), effective from April … Read More

Finland Issues Guidance on Country-by-Country Reporting

Finland Issues Guidance on Country-by-Country Reporting

On December 21, 2016, the Finnish Tax Administration (VERO) issued Draft Guidance A240/200/2016 on country-by-country (CbC) reporting requirements ("Guidance"), the provisions of which entered into force on January 1, 2017. The Guidance provides information on CbC reporting requirements and deadlines, and is aligned with the OECD BEPS Action 13 final report. The first … Read More