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 OECD work on […] … Read More
The OECD has released comments, dated as of August 11, 2017, to the July 11, 2017 public release of the draft contents of the 2017 update to the OECD Model Tax Convention (MTC). The OECD received comments from a variety of international associations and groups. Outlined below are some of the comments received by the […] … Read More
On August 1, 2017, Greece published Law No. 4484 (the “Law”) in the Government newspaper, The Hellenic Democracy. The Law implements EU Directive 2016/881 (amending Directive 2011/16, which was previously amended by Directives 2014/107 and 2015/2376) on the mandatory automatic exchange of tax information (e.g., country-by-country (CbC) reports) into domestic legislation. See BEPS Action 13. […] … Read More
On June 15, 2017, U.K. HMRC issued updated guidance on the Worldwide Disclosure Facility (WDF). See BEPS Action 12. On December 31, 2015, all HMRC offshore facilities closed. The WDF is currently available to anyone who would like to disclose a U.K. tax liability that relates wholly or partly to an offshore issue, which includes […] … Read More
On July 10, 2017, the OECD released its 2017 version of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“TP Guidelines”), which provide guidance on the application of the arm’s length principle. The TP Guidelines define the “arm’s length principle” as “the international standard that OECD member countries have agreed should be […] … Read More
On April 28, 2017, France issued Decree No. 2017-672, ratifying the OECD Multilateral Competent Authority Agreement for the Automatic Exchange of CbC reports (“CbC MCAA”), which was signed in Paris on January 27, 2016. On October 1, 2016, France implemented the CbC reporting requirements introduced in the 2016 Finance Act, which will apply for fiscal […] … Read More