Tax & Accounting Blog

Netherlands Advances Legislation to Substantially Increase Transfer Pricing Documentation Penalties

Netherlands Advances Legislation to Substantially Increase Transfer Pricing Documentation Penalties

On April 18, 2017, the Dutch lower house (House of Representatives) of Parliament adopted legislation (Bill No. 34651 and proposed Amendment No. 9) that would implement EU Directive 2016/881 (the “Directive) on automatic exchange of CbC reporting information among EU member states, and  increase the maximum documentation penalties. However, … Read More

Is Everything Negotiable in Trade?

Is Everything Negotiable in Trade?

In January 2017, I wrote an article shortly after the Trump Administration took office discussing their official withdrawal from the Trans-Pacific Partnership (TPP). This answered my own rhetorical question of whether the U.S. withdrawal effectively killed all new multilateral agreements with the response, “it depends on who you ask.”[1]  Since then, many (including … 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