News

The latest news

SARS - Draft Public Notice Requiring The Submission Of CbC, Master File And Local File Returns
; posted on
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
; posted on
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)
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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
; posted on
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.
Joint Action On Offshore Indirect Assets Tax
; posted on
August 3rd, 2017
The IMF, OECD, UN and World Bank Group released a draft toolkit designed to help developing countries tackle the complexities of taxing offshore indirect transfers of assets. Public feedback on practice of multinational corporations to minimize their tax liability is sought by the Platform for Collaboration on Tax.
Hong Kong - Legislation On Transfer Pricing, CbCR, Dispute Resolution
; posted on
August 3rd, 2017
On July 31, the Hong Kong’s Inland Revenue Department (IRD) has released a consultation report that follows the work of the public on the BEPS plan in 2016, which is to be implemented in Hong Kong. Comments from 26 parties can be found in the report and future policy trends are indicated.
UK Not to Become A Tax Haven
; posted on
August 2nd, 2017
In an interview with French newspaper Le Monde, Chancellor Philip Hammond has said the UK will not reduce taxes or regulations to become a tax haven in a bid to compete with European rivals after Brexit .
Background .
BRICS Agree on Memorandum of Cooperation in Tax Matters
; posted on
August 2nd, 2017
During the annual meeting of the heads of the BRICS revenue administrations held in Hangzhou on July 28, tax officials from Brazil, Russia, India, China and South Africa signed a memorandum of cooperation to enhance their mutual work on international tax matters.
Background: International Taxation .
US Border Tax Proposal Denied
; posted on
August 2nd, 2017
On July 27, a proposed controversial border-adjusted tax proposal was denied in the House of Representatives. In a released statement, the officials informed that the goal of a tax reform is to reduce tax rates “as much as possible,” but the details yet remain unclear.
TPA Global Forms Alliance With Grupo Consultor EFE™ (Mexico)
; posted on
August 1st, 2017
Grupo Consultor EFE™ is an award-winning tax consulting firm with presence in the most entrepreneurial cities in Mexico and LATAM. The firm is the leading transfer pricing advisory services provider for the mid-sized company in the LATAM region, being named Best Transfer Pricing Advisory Firm for the last consecutive years by some of the largest tax-specialized media in the world.
Value Chain Analysis After BEPS - The Roadmap To Being In Control
; posted on
August 1st, 2017
Authors: Steef Huibregtse , Raymund Gerardu and Avisha Sood - TPA Global Network, Amsterdam (the Netherlands).
As Value Chain Analysis is now a mandatory part of the annual TP documentation exercise of MNEs, it can also serve as a.
Research: The Netherlands Is The Main Channel For Corporate Tax Avoidance
; posted on
July 27th, 2017
Almost 40% of corporate investments channeled away from authorities and into tax havens travel through the UK or the Netherlands, according to a study of the ownership structures of 98m firms. The Netherlands was a conduit for 23% of corporate investments that ended in a tax haven, while the UK accounted for 14%, ahead of Switzerland (6%), Singapore (2%) and Ireland (1%).
India - ‘Capital Gains’ Taxation Affair With The Netherlands
; posted on
July 27th, 2017
Andhra Pradesh High Court has concluded that gains arising from a Dutch company’s sale of shares of an Indian immovable property company to a Singapore company do not amount to a sale of immovable property situated in India since India-Netherlands tax treaty exempts such transaction.
Background .
Saudi Arabia To Be The First GCC Country to Implement VAT In 2018
; posted on
July 25th, 2017
Saudi Arabia has issued draft implementing legislation and implementing regulations in preparation of the 1 January 2018 launch of Value Added Tax, VATlive informes. It is based on the Gulf Co-Operation Council (GCC) VAT Treaty, which provides broad guidance on the VAT regime to be introduced in 2018 in all 6 GCC states.
Ireland Launches Apple State Aid Recovery Procurement Process
; posted on
July 25th, 2017
The Irish Ministry of Finance announced the launch of the procurement process in relation to Apple state aid recovery. The Department of Finance also revealed that funds may be higher than initial €13bn estimate.
Cyprus Adjusts Tax Treatment Of Intra-Group Financing Arrangements
; posted on
July 25th, 2017
On July 21, the Cypriot Ministry of Finance informed that the Commissioner of Taxation has issued a Circular for the tax treatment of intra-group financing arrangements. This follows constructive contact with the European Commission's Directorate General for Competition.
New Memory Trainers Will Help You To Become A Knowledgeable VCA, BEPS and/or TP Business Professional
; posted on
July 23rd, 2017
e-Bright is preferred partner of TPA Global.
e-Bright will soon introducing new Memory Trainers that will help you to become a knowledgeable business professional in the following fields:.
India - A Further Step On Tax Info Exchange To Tackle Evasion
; posted on
July 21st, 2017
The Indian Finance Ministry announced that India had taken part in the global joint task force meet to discuss the information exchange issue with other countries as a follow-up work on the Panama Papers.
Collaboration with the JITSIC .
Cayman Islands - Reinforcing Financial Services
; posted on
July 21st, 2017
Cayman's Minister of Financial Services, Tara Rivers, made her first visit to London to meet UK officials and industry leaders addressing its position on Brexit, beneficial ownership, and the EUs work on blacklist of non-cooperative jurisdictions, Cayman iNews reported on July 19.
Reinforcing The Strength Of Cayman's Financial Services .
EU Consults The Public On Customs Information Exchange With 3rd Countries
; posted on
July 21st, 2017
The European Commission opened a consultation to all interested parties on exchange of customs related information with third countries. This view seeking will continue until October 16, 2017.
BEPS Action 8 on Hard-to-Value Intangibles: is this the last piece of the puzzle required by SARS to issue its updated Transfer Pricing Practice Note?
; posted on
July 19th, 2017
One of the main action items identified by South Africa’s National Treasury in its summary of the country’s position on the G20/Organisation for Economic Co-operation and Development (“ OECD ”) action plan on base erosion and profit shifting (“ BEPS ”), is the requirement for the South African Revenue Service (“ SARS ”) to update the Transfer Pricing Practice Note in line with the OECD Transfer Pricing Guidelines to include new guidance on the arm’s length principle and an agreed approach to ensure appropriate pricing on intangibles that are difficult to value.
Action 8 of the BEPS Action Plan mandated the development of transfer pricing rules or special measures for the transfer of Hard-To-Value Intangibles (“ HTVI ”) and the general rules of how to deal with HTVI can be found in section D.
TPA Global Events 2017

We Provide Solutions - Let's Talk Business!

VCA - FUNCTIONAL ANALYSIS POST BEPS
Amsterdam, the Netherlands
25-26 September 2017
 
 
VCA - TRANSFER PRICING WORKSHOP
Kuala Lumpur, Malaysia
3 October 2017
VCA - TRANSFER PRICING WORKSHOP
Jakarta, Indonesia
5 October 2017

* Our global events are held in English unless otherwise indicated.

Copyright © 2017
Transfer Pricing Associates BV.
All rights reserved.

H.J.E. Wenckebachweg 210
1096 AS Amsterdam
T: +31 20 462 3530
E: info@tpa-global.com
I: www.tpa-global.com