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BEPS Action Item 13 aims to improve transparency for tax authorities, advocating a three-pronged approach to transfer pricing documentation including master file, local file, and country-by-country reporting (CbCR). Since its finalization in October 2015, this action item has had a significant adoption rate, with more than 40 countries incorporating these guidelines into local law. The … Read More
The right way to deliver on your BEPS CbCR and notification obligations As countries around the world enact legislation in accordance with Action 13 of the Action Plan on Base Erosion and Profit Shifting (BEPS) set forth by the Organisation for Economic Co-operation and Development (OECD), Multinational Enterprises (MNEs) have common misconceptions — particularly when … Read More
The Transfer Pricing Story There are four elements to an MNE’s transfer pricing story: The CbC report The master file The local file Intercompany agreements How tax authorities detect risk in CbC reports and how MNEs can prepare Now that Country-by-Country (CbC) reporting is an integral part of the compliance process for taxing authorities and … Read More
President Trump won his executive position on a platform touting the inequity associated with trade between China and Mexico, and the negative impact to the United States through the loss of jobs. Earlier this year, he pushed that stance forward by signing a pair of trade safeguards imposing steep tariffs on … Read More
On May 15, 2018, New Zealand published the Finance and Expenditure Committee’s (the “Committee’s”) amendments to the Taxation (Neutralising Base Erosion and Profit Shifting) Bill (the “Bill”). Part 1 of the Bill (i.e., hybrid and branch mismatches, interest limitation, permanent establishment (“PE”), transfer pricing) would amend the … Read More
What’s the buzz with Big Data, and what does it mean to us as tax and accounting professionals? Big data, the cloud, artificial intelligence, API’s…all terms we see, but it’s hard to know what’s relevant to your firm and where to invest our learning resources. This article is my best attempt to connect the dots … Read More