BEPS
Singapore Issues e-Tax Guide for Country-by-Country Reporting
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October 13th, 2016
The Inland Revenue Authority of Singapore (IRAS) issued an e-Tax Guide on Country-by-Country Reporting. Singapore-headquartered MNEs meeting certain conditions are required to prepare and file CbC Reports to the IRAS for financial years beginning on or after January 1, 2017.
BEPS and Transfer Pricing in MNCs: Policy Considerations and Practices
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October 11th, 2016
The changes proposed by the OECD BEPS Action Plan in October 2015 have the potential to substantially challenge the whole tax and transfer pricing landscape for many taxpayers. More specifically, with a radical attack on preferential regimes and tax avoidance schemes and enhanced transparency through, for example, for example, Country-by-Country (“CbC”) reporting, tax authorities and other governmental units will be able to understand and where appropriate challenge how MNEs allocate their profits and taxes globally.
Tax Risk Management & Transfer Pricing for Life Sciences
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September 22nd, 2016
As regulations around the world become both more numerous and stringent, and enforcement and penalties increase in the highly regulated life sciences sector, companies may benefit from taking a risk-based approach to tax planning compliance, execution, and tracking.
The conference agenda will focus on the most problematic areas in tax risk management such as tax compliance and governance, transfer-pricing and country-by-country reporting issues management and others:
New Course: Transfer Pricing – BEPS for Beginners
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September 14th, 2016
e-Bright and TPA Global have launched the 4th course of the Transfer Pricing courses
‘BEPS for Beginners’
OECD to Hold First 'Inclusive Framework for BEPS Implementation' Meeting
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September 7th, 2016
On June 30 and July 1, representatives of countries and jurisdictions worldwide will gather in Kyoto, Japan, for a first meeting of the inclusive framework organized to take forward the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project.
Governance, Structure and Work Program
OECD Publishes Comments On Amendments To Chapter IX TP Guidelines
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August 26th, 2016
On August 24, The OECD published the comments it received on the conforming amendments to Chapter IX of the OECD Transfer Pricing Guidelines, "Transfer Pricing Aspects of Business Restructurings."
Background
OECD Releases Discussion Draft On Branch Mismatch (Action 2)
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August 24th, 2016
The OECD invited interested parties to provide comments on branch mismatch structures under Action 2 (Neutralizing the Effects of Hybrid Mismatch Arrangements) of the BEPS Action Plan.
Background
OECD Releases Discussion Draft On Branch Mismatch (Action 2)
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August 24th, 2016
The OECD invited interested parties to provide comments on branch mismatch structures under Action 2 (Neutralizing the Effects of Hybrid Mismatch Arrangements) of the BEPS Action Plan.
Background
BEPS implemented into the LATAM countries: what is happening in that region?
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August 4th, 2016
In the case of LATAM countries the majority are not OECD members and their contribution to BEPS measurements has been limited. Nevertheless, some LATAM countries already have or have announced to implicitly or explicitly implement regulations that are anti-BEPS.
OECD - Discussion Draft on Action 4 in the Banking and Insurance Sectors
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August 3rd, 2016
The OECD invited interested parties to provide comments on a discussion draft which deals with approaches to address BEPS involving interest in the banking and insurance sectors under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Action 4 - Background
OECD - Discussion Draft on Action 4 in the Banking and Insurance Sectors
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August 2nd, 2016
The OECD invited interested parties to provide comments on a discussion draft which deals with approaches to address BEPS involving interest in the banking and insurance sectors under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Action 4 - Background
Insights into BEPS Implementation By MNEs
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July 22nd, 2016
A new 2016 Global BEPS Readiness Survey examined how multinational enterprises are reacting to and preparing for the BEPS, revealing problems multinationals have adjusting to the new rules. The findings uncovered trends, revealed risks and exposed pain points on a global scale.
Insights into BEPS Implementation By MNEs
; posted on
July 21st, 2016
A new 2016 Global BEPS Readiness Survey examined how multinational enterprises are reacting to and preparing for the BEPS, revealing problems multinationals have adjusting to the new rules. The findings uncovered trends, revealed risks and exposed pain points on a global scale.
Jamaica Joins Inclusive Framework on BEPS Implementation
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July 21st, 2016
The OECD announced that Jamaica has become the 85th member of the Inclusive Framework on BEPS Implementation. The OECD informed that more countries that attended the Kyoto meeting on June 30, are expected to join the Framework.
OECD Releases Discussion Draft on Group Ratio Rule (Action 4)
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July 11th, 2016
On July 11, the OECD invited interested parties to provide comments on a discussion draft which deals with elements of the design and operation of the group ratio rule under Action 4 (Interest deductions and other financial payments) of the BEPS Action Plan.
Fixed Ratio Rule
OECD Releases Two Discussion Drafts on BEPS Actions 7 and 8 - 10
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July 6th, 2016
The OECD has released BEPS discussion drafts on attribution of profits to permanent establishments, which deals with work in relation to BEPS Action 7, and revised guidance on profit splits, which deals with work in relation to BEPS Actions 8-10.
Discussion Draft - Action 7
OECD Releases Guidance on the Implementation of CbC Reporting
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July 1st, 2016
The OECD has released guidance on implementing country-by-country (CbC) reporting, as set out in Action 13 Report “Transfer Pricing Documentation and Country-by-Country Reporting” of the base erosion and profit shifting (BEPS) project.
Country-by-Country Reporting
How to make intercompany loans BEPS proof
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March 17th, 2016
In this article we provide four “true or false” statements on how the intercompany debt financing has become vulnerable and how to resolve the transfer pricing issues around that.
Debt as intercompany financing with excessive interest deductions has come under greater scrutiny of the tax authorities after the OECD published its final work on Action Points relating to intercompany financing in October last year.
Dissecting BEPS Action Plan 6 Preventing The Granting Of Treaty Benefits In Inappropriate Circumstances
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December 10th, 2014
Action Plan 6 of the BEPS Action Plan identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns.
The most important aspects of the report are :
Specialties
Country expertise
Industries
BEPS
May 10th, 2016
BEPS
; posted on
May 10th, 2016

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