Tax & Accounting Blog

Ireland House of Representatives Supports Appeal of Apple State Aid Ruling

Ireland House of Representatives Supports Appeal of Apple State Aid Ruling

On September 7, 2016, Irish Finance Minister Michael Noonan spoke to the House of Representatives (Dáil Éireann), seeking support to appeal the European Commission's decision that tax rulings issued by Ireland to Apple in 1991 and 2007 constituted illegal stated aid. On the same date, the Irish Department of Finance issued … Read More

UK Parliament agrees to give HM Treasury power to require public CbC reporting

UK Parliament agrees to give HM Treasury power to require public CbC reporting

The UK Parliament has been debating the large omnibus Finance Bill 2016 which, among other things, contains amendments concerning transfer pricing (application of OECD principles) as well as other amendments re hybrid mismatches, DPT amendments, a patent box regime in the UK, GAAR, etc. A critical amendment to the Bill, agreed to by … Read More

UK Launches Worldwide Disclosure Facility

UK Launches Worldwide Disclosure Facility

On September 5, 2016, HMRC published the Guidance on the Worldwide Disclosure Facility (WDF) that is available for disclosure of a UK tax liability relating wholly or partly to an offshore interest. Prior to December 31, 2015, HM Revenue and Customs (HMRC) offered incentives to encourage taxpayers to voluntarily disclose their tax positions. … Read More

KPMG’s Joseph Pari on the U.S. Proposed Section 385 Regs.

KPMG’s Joseph Pari on the U.S. Proposed Section 385 Regs.

Joseph M. Pari is the national principal-in-charge of the Washington National Tax practice of KPMG LLP. He is based in Washington, D.C.  Prior to joining KPMG, he was a partner at the law firms of Linklaters LLP and Dewey Ballentine/Dewey & LeBoeuf LLP. Mr. Pari answered the following questions for BEPS Global Currents on September … Read More

Apple’s €13 billion Irish back-tax bill reverberates around the world – Apple and Ireland to appeal; U.S. denounces decision

Apple’s €13 billion Irish back-tax bill reverberates around the world – Apple and Ireland to appeal; U.S. denounces decision

Let the tax wars begin! A little too dramatic? Perhaps, but maybe not. The significance of the European Commission's decision effectively imposing a €13 billion (yes, €13 billion!) Irish back-tax bill on Apple should not be underestimated. While it may take a little time for the consequences to be fully worked through, the decision raises … Read More

Romania Issues Guidance on Automatic Exchange of Financial Account Information

Romania Issues Guidance on Automatic Exchange of Financial Account Information

On August 24, 2016, Romania’s Ministry of Public Finance issued guidance (Order No. 1939/2016) on automatic exchange of financial account information (AEOI) under the U.S. Foreign Account Tax Compliance Act (FATCA) regime and OECD Common Reporting Standard (CRS). Financial institutions in Romania have to begin reporting FATCA information by August 31, 2016, and … Read More