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On November 15, 2017, Argentina issued its draft tax reform bill, which includes a number of BEPS measures. These measures are discussed below. Value Added Tax (VAT) (BEPS Action 1) This bill proposes to incorporate legislation regarding digital services where the provider is resident or domiciled outside Argentina, to the extent … Read More
On November 14, 2017, the U.K. House of Commons held an emergency debate on tax avoidance and evasion ahead of Chancellor Philip Hammond’s finalization of the Budget. During the debate, members emphasized the need for public country-by-country (CbC) reporting following the release of the Paradise Papers. See BEPS Action 13. According to Dame … Read More
The drive for global tax transparency continues to gain speed while financial institutions (FIs) also grapple with emerging disruptive financial technology innovations and growing threats to data security. Building on the U.S.-led FATCA regulations, the first wave of reporting for the OECD-led initiative, the CRS, includes 49 jurisdictions undertaking the first exchange of financial information … Read More
On October 27, 2017, Belgium issued an overview of tax reform proposals, several of which implement EU Directive 2016/1164 of July 12, 2016 (ATAD 1) (the “Directive”) regarding hybrid mismatches, controlled foreign companies (CFCs) and limitation on interest deductions. On October 27, 2017, the Belgian Ministry of Finance also announced … Read More
On October 31, 2017, the Mexican tax authority (Servico de Administracion Tributaria or SAT) announced that its online platform and electronic forms will be ready starting on November 1, 2017, for taxpayers to file their new transfer pricing documentation (i.e., country-by-country (CbC) report, master file, and local file). Editor’s Note: This means that there … Read More
On October 27, 2017, a U.S. Internal Revenue Service (IRS) Large Business and International (LB&I) official, Theodore Setzer (Assistant Deputy Commissioner – International), said during an ABA Tax Section conference in Washington, D.C. that the IRS may not be able to sign some bilateral competent authority agreements (CAAs) in 2017 with its treaty partners … Read More