PwC BEPS webcast: A focus on hybrid mismatch arrangements (27 March)
Date: 27 March 2014 Time: 12:00 pm to 1:00 pm ET Duration: 60 minutes (including Q&A) Click here to register With the 19 March 2014 release of the discussion draft on Action 2 (Neutralise the effects of hybrid mismatch arrangements) of the Base Erosion and Profit Shifting (BEPS) Action Plan, we continue our series of
Tax authorities target the partial exemption of remittance of Belgian withholding taxes
The amount of Belgian withholding taxes is based on the withholding income tax scales published in a Royal Decree. The Belgian income tax code foresees several exemptions (overtime, research and development, night and shift work, …) with respect to the remittance of Belgian withholding taxes. In this respect, it should be noted that the Belgian tax
Recent FATCA developments from the IRS & US Treasury
The following are recent FATCA developments from the IRS and US Treasury. 1. IRS begins issuing GIINs FFIs have reported that their accounts have been updated to include the Global Intermediary Identification Number (GIIN) assigned by the IRS. The notification that a GIIN has been assigned is an email from the address fatca-donot-reply@irs.gov to log into
OECD releases discussion draft on the use of treaty benefits in inappropriate circumstances
This OECD report calls for a very significant rewrite of both the OECD Model Tax Convention and the Commentary, including a US-style Limitation of Benefits (LoB) article as well as a main purpose anti-abuse rule. A variety of other anti-abuse measures are also proposed. If the recommendations are widely adopted, they will undoubtedly reduce treaty
Belgian tax authorities can copy and seize computerised information of taxpayers
The Belgian tax authorities have a broad view on their investigation powers as regards to computerised information. Recent case law seems to approve this broad view. After the tug-of-war between the Belgian taxpayers and the Belgian tax authorities regarding the competences of the latter to investigate, copy and seize computerised (digital) information, it seems that
OECD – Paper on transfer pricing comparability data and developing countries released for comment
On March, 11th 2014, the OECD released a paper on transfer pricing comparability data and developing countries for comment. The paper sets out and briefly discusses four possible approaches to address the concerns over the lack of data on comparables expressed by developing countries. Background OECD and non-OECD countries frequently express concerns about the availability
Update on FATCA-related IRS forms
Please find below the status of FATCA-related forms and instructions. Links are included when available. The list will be updated and recirculated as additional forms are released by the IRS. Form w/ link Title Status 2014 Form 1042 Instructions Annual Withholding Tax Return for U.S. Source income of Foreign Persons Final 2014-03-04 2014 Form 1042-S
Panel debate on the changing Belgian TP landscape
On 25 February 2014, a flagship event was held reflecting on the changing transfer pricing (TP) environment in Belgium. Two senior representatives from the Belgian administration and one delegate from the Organisation for Economic Cooperation and Development (OECD) shared interesting insights during a panel debate on how they feel that the Base Erosion and Profit Shifting (BEPS) project