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Four Countries Ask EU To Take More Effective Measures To Plug Tax Evasion By Digital Economy
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September 13th, 2017
On September 9, Finance Ministers of France, Germany, Italy and Spain jointly issued a political statement. In the document, the Member States appealed the European Commission to take more effective measures to plug tax evasion by digital economy.
The UN Publishes New Handbook on Developing Countries’ Tax Base
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September 12th, 2017
UN has published a new Handbook on several selected issues to assist developing countries to guard their tax base and strengthen their capacity to gather domestic revenue. The Handbook is the fruit of a project undertaken by the Financing for Development Office on the basis of draft papers discussed at a workshop in June 2014 in New York and in September 2014 in Paris.
EU Plans Rule Change - Online Tech Giants To Be Taxed Where They Create Value
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September 7th, 2017
The Estonian presidency of the EU released a document prepared for the meeting of the EU Finance Ministers on September 15, 2017 in Tallinn, Estonia. The meeting will discuss how to plug evasion by digital multinationals, and the document alleged that the current legal framework should be amended as it in effect favors digital companies.
UK - Extension Of Deadline On Trusts Tax Planning Register
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September 7th, 2017
HM Revenue & Customs (HMRC) has extended its time constraint on the registration of trusts for money laundering supervision. The previous deadline of October 5, 2017 is extended to December 5, 2017.
Tax Technology Event 2017 - From ‘Staying Out Of Trouble’ To ‘Being In Control’
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September 7th, 2017
This workshop is organized to assist businesses in finding their way through the world of tax technology solutions.
Thursday, 7 September 2017
France - Second Highest Tax Bill To Be Paid By Tech Giant
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September 6th, 2017
The French Microsoft subsidiary received a notification from the French tax competence. The multinational was required to pay a 600 million euros bill in France for its activities regarding online advertising and search engine.
EU Notice on Freedom of Capital: Commission vs. France Published
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September 6th, 2017
The Action (2017/C 293/27) brought on July 10, 2017 by the European Commission versus the French Republic has been published in the Official Journal of European Union. The Action was about a French national provision on tax treatment of dividends, which the Commission finds discriminatory and may restrict the free movement of capital.
BRICS Countries Announced to Plug Evasion
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September 6th, 2017
The leaders of Brazil, Russia, India, China and South Africa met at the ninth BRICS Summit and jointly issued the BRICS Leaders' Xiamen Declaration. The declaration discussed international and regional issues of common concern, including facilitating tax cooperation to plug evasion and provide technical assistance regarding tax governance.
Self-assessment Of Tax Risk By MNEs With A Centralised Business Model - A New Tax Screening Tool Developed By The ATO
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September 1st, 2017
In early 2017, the Australian Tax Office (‘ATO’) released a guideline, setting out a compliance approach to assess the transfer pricing outcomes based on self-assessment of tax risks in existing and newly created offshore centralised operating models (‘hubs’). This guideline is applicable from 1 January 2017 to hubs performing a wide range of activities such as the marketing, sale, distribution and procurement of goods and commodities as well as financial services.
Luxembourg - Legislation On Mutual Agreement Procedure
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August 31st, 2017
Luxembourg issued a Circular (L.G. - Conv. D.I. n° 60) on procedures for the implementation of the Mutual Agreement Procedure (MAP) for bilateral tax treaties concluded by Luxembourg.
Scope and Access .
Ecuador - Amendments on Withholding Tax Rates
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August 31st, 2017
the Ecuadorian Internal Revenue Service published a resolution to amend the previous resolution on the income tax withholding rates at source. The new resolution comes into force since its issue.
UN Appoints 25 Members To The Committee Of Experts On International Cooperation In Tax Matters
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August 30th, 2017
The Committee of Experts on International Cooperation in Tax Matters comprised 25 members nominated by Governments and acting in their personal capacity. The members are drawn from the fields of tax policy and tax administration and selected to reflect an adequate equitable geographical distribution, representing different tax systems.
Belgian DTAs With Mexico And Uruguay Enter Into Force
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August 29th, 2017
The Belgian Ministry of finance issued a press release, announcing that the Protocol amending the existing Belgian – Mexican Double Taxation Agreement (DTA) entered into force on August 19, 2017. At the same time, Belgian Ministry of finance announced that the DTA between Belgium and Uruguay entered into force on August 4, 2017.
ATO Aims At Big Pharmaceuticals
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August 29th, 2017
Deputy ATO commissioner Mark Konza told Parliament that ATO's ongoing corporate investigations are looking at companies in the pharmaceutical industry. ATO has already interviewed between 30 and 40 employees in one of the large pharmaceutical companies and has launched another 12 audits of big pharma companies.
PANA Publishes A Study Addressing Member States' Anti-Tax-Avoidance Capacity
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August 25th, 2017
The European Parliament's Committee of Inquiry into Money laundering, tax avoidance and tax evasion (PANA) published a new study addressing Member States' capacity to fight tax crimes. The study consist of ex-post impact assessment and investigates national provisions to combat tax avoidance and tax evasion, plus money laundering laws and their enforcement.
Tech Giant Reaches Undisclosed Settlement With Australian Tax Office
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August 25th, 2017
Microsoft announced this week that it has settled the Australian tax audit. At the same time, Apple's managing director informed that the five-year audit by the ATO has been concluded with no penalty imposed.
US Court Rules IRS Lawfully Denied Discretionary Tax Treaty Benefits
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August 25th, 2017
On August 14, the United States District Court for the District of Columbia ruled in Starr International Company, Inc. v. United States case that the Internal Revenue Service (IRS) was not arbitrary or capricious in finding at least one of the taxpayer’s principal purposes for moving its residency to Switzerland was to obtain tax benefits under the US-Swiss Treaty.
SARS - Draft Public Notice Requiring The Submission Of CbC, Master File And Local File Returns
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August 23rd, 2017
This draft public notice requires specified persons to submit returns in respect of transfer pricing documentation for reporting fiscal years and financial years commencing on or after 1 January 2016.
The proposed deadline for submission will be 12 months from the last day of the reporting fiscal year, in the case of country-by-country returns, and 12 months from the last day of the financial year, in the case of the master file and local file.
China - New Measures to Boost Foreign Investment
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August 22nd, 2017
On August 16, 2017, China’s State Council issued a notice (Guo Fa [2017] No.39) on measures to boost foreign investments.
Singapore - A Positive Response to Digital Economy (GST)
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August 22nd, 2017
During the SMU-TA Centre for Excellence in Taxation Conference on August 17, Ms. Indranee Rajah, Senior Minister of State for Law and Finance, announced the state’s resolution on revising its Goods and Services Tax (GST) of digital economy and future policy orientation.
HMRC Publishes Additional Guidance on CbC Reporting
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August 17th, 2017
On August 15, the HMRC published guidance on country-by-country reporting titled as “Check if you must send a country-by-country report” and "Country-by-Country XML Schema Guidance." The XML Schema Guide provides information on specific data elements and any attributes that describe that data element.
EU Releases a Taxation Paper on R&D Under a CCCTB
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August 17th, 2017
An assessment of R&D Provisions under a Common Consolidated Corporate Tax Base written by Diego d’Andria, Dimitris Pontikakis and Agnieszka Skonieczna has been published by the European Commission in its Taxation Papers publications. The outcomes of the paper conclude that the CCCTB without an R&D incentive would significantly deteriorate incentives to invest in R&D.
South Africa - Retrospective Country-by-Country Reporting And Transfer Pricing Documentation Requirements
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August 16th, 2017
South Africans who think that their tax burden is going to decrease because country-by-country (“ CbC ”) reporting does not apply to their company should think again!
In addition to the recently released draft notice requiring the submission of CbC reports, master file and local file returns, the South African Revenue Service (“ SARS ”) has recently issued the External Business Requirements Specification (“ BRS ”) document, setting out CbC and Financial Data Reporting (“ FDR ”) requirements..
IRS Is Now Accepting Country-by-Country Reports
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August 15th, 2017
On August 11, the IRS issued a press release announcing that it is now accepting country-by-country (CbC) reports and advised that parent entities of US multinational enterprise groups should now file Form 8975 with their annual income tax return.
US Multinationals to File CbC Reports .
France and Germany Target US Home-Sharing Platform Giant
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August 15th, 2017
Airbnb faces EU clampdown for not paying 'fair share' of tax as France and Germany initiate a new European Union fight to force home-sharing platforms to pay more tax. The French finance minister Bruno Le Maire said Airbnb’s low tax bill was “unacceptable”.
ATO to Collect CbC Information from the US
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August 15th, 2017
The US and Australia have agreed to share detailed information of companies as countries signed a country-by-country report agreement. The Australian Labor party also proposed a private senators’ bill on Monday that would require private companies with more than $100m in turnover to release their annual tax information to the public.
US Tech Giants Will Face Tax Clampdown from France and Germany
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August 10th, 2017
France and Germany and other partners have paired up to secure loopholes allowing U.S. tech giants such as Alphabet Inc.’s Google, Apple Inc., Facebook Inc. and Amazon.com Inc. to reduce taxes and take hold of market share in Europe, at the cost of European companies.
Cyprus - New Transfer Pricing Rules on Intra-Group Loan
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August 10th, 2017
Cyprus Tax Department has published a new circular regarding detailed transfer pricing rules which came into force on July 1, 2017. The new rules replaced the existing rules to determine the tax base of the “back-to-back” intra-group loan on the basis of a minimum margin.
Argentina - Brazil Tax Treaty: Latest Revision
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August 10th, 2017
Argentina and Brazil signed a protocol on several significant amendments on the bilateral tax treaty between the two countries during the Mercosur Summit. The new version, however, is not in force yet, as future feedback from the public may be needed.
New Zealand - BEPS Decision on Multinationals
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August 7th, 2017
The New Zealand government confirmed final decisions regarding taxation of multinationals to address Base Erosion and Profit Shifting (BEPS) and facilitate a fairer taxation. All these changes will be implemented via a tax bill and come into force by July 2018.
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