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Workshop For Corporates - "Fit For Future: A Refined Approach To Tax Risk Management"
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May 9th, 2019
During the past few years, the EU commission and many local governments have released a number of aggressive and uncoordinated initiatives to curb unwanted tax behaviour of multinationals, following the 2015 release of the BEPS Action Plans by the OECD/G20.
Consequently, MNEs are experiencing an increased exposure to tax controversies if they are not simultaneously in control of their Operating and Tax/Transfer Pricing models.
OECD Beneficial Ownership Toolkit To Build Up Tax Transparency
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March 21st, 2019
The OECD has released a beneficial ownership toolkit, which will give law enforcement access to information on beneficial owners of companies to make it more difficult for criminals to hide illicit tax evasion activities.
Background .
UK Issues Tax Guidance On No-Deal Brexit Scenario For Interest, Royalty, And Dividend
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March 21st, 2019
The EU Interest and Royalties Directive (IRD) and Parents Subsidiary Directive (PSD) allow EU companies to make certain interest and royalties payments to associated companies and permanent establishments within the EU without needing to deduct tax from them. However, if the UK leaves the EU without a deal on 29 March 2019, these directives will no longer apply to the UK.
Costa Rica Publishes Amending Resolution To Clarify CbC Reporting Requirements For Multinational Groups
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March 21st, 2019
Costa Ricas’ Government has published Resolution No. DGT-R-008-2019 in the Official Gazette. The Resolution amends Resolution DGT-R-001-2018, which regulated the information that companies based in Costa Rica need to report for the purposes of automatic exchange of country-by-country (CbC) reports in accordance with the OECD's BEPS Action 13.
EU Report: The Implementation Of CCCTB Might Reduce The Effective Tax Burden
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March 19th, 2019
The European Commission published Taxation Paper No. 75 related to Common Consolidated Corporate Tax Base (CCCTB), which aims at evaluating the impact of the CCTB on the effective corporate tax burdens in the 28 EU Member States and assessing the relative importance of single elements of the harmonized tax base.
EU Joint Transfer Pricing Forum To Continue Profit-Split Work
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March 19th, 2019
In light of the profit-split method’s potentially expanded role under a new regime for taxing the digital economy, the EU Joint Transfer Pricing Forum (JTPF) will explore ways to improve the method’s clarity and simplicity. As complementary to the OECD guidance, the report highlights two important parts, justification in applying Profit Split Method) PSM and the key allocation that can be used to split the profit.
How Technology Is Changing Taxation In Latin America
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March 18th, 2019
This article provides an overview of the important role played by technology in taxation and transfer pricing in Latin America, and presents comprehensive research to illustrate the digital path taken by tax administrations and corporations in Latin America and worldwide.
Given current developments in taxation, taxpayers and tax authorities face numerous challenges that result from an era of data gathering and full-transparency.
IMF Publishes Policy Paper To Assess International Tax Reform Proposals
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March 14th, 2019
The International Monetary Fund (IMF) has published a policy paper on Corporate Taxation in the Global Economy. Through its paper, the IMF has stressed that international tax rules should be reformed to prioritize reducing the glaring inequalities that lower-income countries face when it comes to their taxing rights.
EU Economic And Financial Affairs Council Decides To Add Ten Additional Jurisdictions To Non-Cooperative List
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March 14th, 2019
The EU Economic and Financial Affairs Council has issued a release on the main results from its 12 March 2019 meeting, including that it has adopted a revised list of non-cooperative jurisdictions for tax purposes. In addition to the five jurisdictions that were already listed, American Samoa, Guam, Samoa, Trinidad and Tobago and the U.
Dutch Government Issues Draft Decree On Transitional Tax Rules In The Case Of No-Deal Brexit
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March 14th, 2019
The Dutch State Secretary for Finance sent a draft decree containing a temporary transitional regime applying in the event of a "no-deal" Brexit to the lower house of the Parliament.
Background .
The Next Generation of Benchmarking
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March 14th, 2019
Value Chain Analysis (VCA) was incorporated into the regulations following the OECD/G20 BEPS initiative (BEPS Actions 8 - 10), and subsequently, embedded in the OECD Transfer Pricing Guidelines 2017.
The importance of VCA in the OECD Transfer Pricing Guidelines, 2017, is revealed in their collective title: “ Aligning Transfer Pricing Outcomes with Value Creation ”.
The Netherlands Updates Decree On Application Of Participation Exemption
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March 12th, 2019
The Dutch government updated Decree on the application of the participation exemption (the Decree) with effect from 9 March 2019, having retroactive effect to 13 February 2019. The clarification and amendments of the Decree relates to the application of option rights and simplification of dissolution procedure to the extent the subsidiary has been declared bankrupt or the decision to liquidate the holding has been taken, yet the liquidation has not been completed.
European Commission Warns Spain And Finland To Amend Their Discriminative Tax Policies
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March 12th, 2019
The European Commission published its Infringement Package for March 2019, which includes the infringement in the taxation area. In response to that, the European Commission sent a letter to Spain to eliminate discrimination on capital gains taxation and to Finland to bring its rules on tax deductibility of group contributions in line with EU law.
Spain And The UK Sign Tax Agreement On Gibraltar To Combat Tax Fraud And Money Laundering
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March 7th, 2019
Spain's Ministry of Foreign Affairs, the European Union, and Cooperation has announced the signing of a tax agreement with the UK concerning Gibraltar. The agreement is designed to combat tax fraud and money laundering in Gibraltar once the UK leaves the European Union and includes new rules on tax residency for both individuals and companies.
Luxembourg To Reduce Corporate Tax Rate And Amend Interest Limitation
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March 7th, 2019
The Ministry of Finance in Luxembourg presented the Budget 2019 to the parliament. Citing the need to remain competitive, the government of Luxembourg has proposed a 1 percent point reduction in the corporate tax rate and a more flexible interest expense limitation for consolidated corporate groups (fiscal unity).
Ireland Issues Research And Development (R&D) Tax Credit Guidance
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March 7th, 2019
The Irish Revenue has issued tax and duty manual revisions regarding changes to research and development tax credit guidelines.
Qualifying Recipient
France Releases A More Detailed Proposal For GAFA (Google, Apple, Facebook, Amazon) Tax
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March 5th, 2019
The French Minister of Economy on March 3 released more details on the proposed 3% digital tax, the so-called GAFA (Google, Apple, Facebook, and Amazon) tax on turnover. The bill is scheduled to be approved by the Cabinet on March 6 and then submitted to parliament.
EU Parliament TAX3 Special Committee Adopts Report On Fairer And More Effective Taxation And Tackling Financial Crimes
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March 5th, 2019
The European Parliament has announced that the special committee on financial crimes, tax evasion and tax avoidance (TAX3) has adopted a report on fairer and more effective taxation and tackling financial crimes.
Measures Initiated by TAX3 .
USA Supports A Push By France For A Minimum Corporate Taxation On Corporations
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March 1st, 2019
The United States supports France to implement minimum corporate taxation and hopes for an OECD solution to taxing the digital economy before the end of 2019. The supports were conveyed by Treasury Secretary Steven Mnuchin during a joint press conference with French Finance Minister Bruno Le Maire in Paris.
Germany To Grant Tax Breaks Worth 1.5 Billion Euros For R&D
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March 1st, 2019
The German government is reportedly working to finalize plans for the introduction of new tax incentives for research and development (R&D). The government first included support for the introduction of new incentives for SMEs and start-ups as part of plans agreed to at the beginning of 2018.
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