Tax & Accounting Blog

Deloitte’s Sally Morrison on the U.S. Section 385 Final Regs.

Deloitte’s Sally Morrison on the U.S. Section 385 Final Regs.

Sally Morrison is a partner and leader within the International Tax and Global Strategies practice of Deloitte Tax LLP in Kansas City, Missouri. On November 21, 2016, Ms. Morrison answered the following questions for BEPS Global Currents, regarding the Section 385 final Regulations (T.D. 9790) (“Final Regulations”) published in the Federal Register on … Read More

Netherlands Delays First Notification of CbC Reporting

Netherlands Delays First Notification of CbC Reporting

On November 15, 2016, the Dutch State Secretary of Finance issued a decree, delaying the first notification deadline for country-by-country (“CbC”) reporting to September 1, 2017. The tax authorities have developed an automatic notification tool, which the State Secretary intends to make compulsory. The notification is made pursuant to Section 29d of the Read More

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