Tax & Accounting Blog

BEPS Action Item 13: Using Technology to Simplify Compliance

BEPS Action Item 13: Using Technology to Simplify Compliance

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

Can you satisfy your BEPS CbCR and notification obligations with a spreadsheet?

Can you satisfy your BEPS CbCR and notification obligations with a spreadsheet?

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

Detecting Risks in CbC Reports in a Post-BEPS Era

Detecting Risks in CbC Reports in a Post-BEPS Era

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

New Zealand Proposes Amendments to Draft BEPS Bill

New Zealand Proposes Amendments to Draft BEPS Bill

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

U.K. Parliamentary Committee Approves Draft Order to Implement MLI

U.K. Parliamentary Committee Approves Draft Order to Implement MLI

On May 9, 2018, several members of the U.K. Parliament and the Financial Secretary to the Treasury, Mel Stride, debated and approved the draft order (Double Taxation Relief (Base Erosion and Profit Shifting) Order 2018) of March 28, 2018 during a meeting of the Third Delegated Legislation Committee. The legislation … Read More

EY’s Terry Cardew on Banks’ Response to the U.S. TCJA

EY’s Terry Cardew on Banks’ Response to the U.S. TCJA

Terry Cardew is Banking & Capital Markets tax leader for EY’s Financial Services Office. His experience includes a variety of tax planning, consulting, and compliance projects for multi-national financial services companies headquartered in the U.S. and outside the U.S., as well as for various global real estate funds and alternative investment vehicles. In his current … Read More