Tax & Accounting Blog

U.S. Publishes Additional Model Competent Authority Agreement on Exchange of Country-by-Country Reports

U.S. Publishes Additional Model Competent Authority Agreement on Exchange of Country-by-Country Reports

On September 12, 2017, the U.S. Internal Revenue Service (IRS) published a model competent authority agreement (CAA) for the exchange of country-by-country (CbC) reports that is based on the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters (the “OECD Convention”). The foregoing CAA supplements the CAAs that the IRS published on … Read More

Ireland Reviews Corporation Tax Code in Light of BEPS

Ireland Reviews Corporation Tax Code in Light of BEPS

On September 12, 2017, Ireland’s Minister for Finance and Public Expenditure and Reform released the independent report of Mr. Seamus Coffey on Ireland’s Corporate Tax Code in relation to the OECD BEPS project. The recommendations in the report will be considered by the Irish government. Ireland’s commentary from the Report with respect to specific … Read More

U.S. IRS Publishes More Bilateral CbC Report Exchange Information

U.S. IRS Publishes More Bilateral CbC Report Exchange Information

On September 13, 2017, the U.S. IRS published the bilateral competent authority arrangement (CAA) that it signed with Lithuania on August 30, 2017, on the exchange of country-by-country (CbC) reports. This CAA is based on the 1998 income tax treaty  in effect with Lithuania. Article 27 (Exchange of Information) of the U.S.-Lithuania … Read More

Greece Announces Implementation of EU Directive on Automatic Exchange of Country-by-Country Reports

Greece Announces Implementation of EU Directive on Automatic Exchange of Country-by-Country Reports

On August 24, 2017, Greece issued Circular 1131 with respect to Law No. 4484-2017 (published in the official gazette on August 1, 2017), which implemented EU Directive 2016/881 (the “Directive”) into Greek legislation regarding the mandatory automatic exchange of country-by-country (CbC) reports. See BEPS Action 13. The Directive amends Directive 2011/16, … Read More

Portugal Implements EU Directives on Exchange of Tax Rulings and CbC Reports

Portugal Implements EU Directives on Exchange of Tax Rulings and CbC Reports

On August 24, 2017, Portugal published Law No. 98/2017 in the official gazette, which implements EU Directives 2015/2376 and 2016/881 on the automatic exchange of tax ruling and CbC reporting information among EU member states, respectively. The measures apply retroactively from January 1, 2017. Tax Rulings (BEPS Action 5) Building on the … Read More

OECD Releases Additional Guidance on Country-by-Country Reporting

OECD Releases Additional Guidance on Country-by-Country Reporting

On September 6, 2017, the OECD’s Inclusive Framework on BEPS released two sets of guidance for tax administrations and MNE groups regarding the implementation and operation of country-by-country (CbC) reporting. See BEPS Action 13. Existing guidance on the implementation of CbC reporting has been updated to address the following issues: Definition of … Read More