Aligning transfer pricing outcomes with value creation – Revised chapters I, II, VI and VII of the OECD Transfer Pricing Guidelines
On 5 October 2015, the OECD presented its final package of Base Erosion and Profit Shifting (BEPS) measures for a comprehensive, coherent, and co-ordinated reform of the international tax rules. The package was endorsed by the G20 Finance Ministers at their meeting on 8 October 2015, in Lima, Peru. This final package (referred to below
Agreement on automatic exchange of information within the EU
On 6 October 2015, the EU Finance Ministers reached political agreement in the Council to amend Directive 2011/16/EU on administrative cooperation in the field of taxation. The revised directive will require member states to automatically exchange a basic set of information on advance cross-border tax rulings (rulings) and advance pricing arrangements (APAs), both of which
New administrative VAT decision: Travel package and insurance services – Impact for Belgian lease industry
The Belgian VAT authorities have published a new administrative decision clarifying the VAT treatment of offerings by travel agencies consisting of both travel services and insurance services, based on the ‘old’ CJEU case BGZ Leasing of 2011 (C-224/11). These guidelines adjust the initial viewpoint of the Belgian VAT authorities to the CJEU case BGZ Leasing
Belgium: new agreement on Tax Shift
On 10 October 2015, the Belgian federal government reached a new agreement on the so-called “tax shift”. The tax shift is the shift from tax on labour to other taxes. The objectives of the tax shift are: To respect the budgetary engagements; A revival of the economy by creating more jobs; Reducing labour taxes to
Is your upper-tier structure BEPS-proof?
The OECD BEPS Action Plan and parallel developments impact each layer of a multinational structure, including the upper tier. Specifically, having insufficient relevant substance at upper tier level could cause your return on investment to decrease significantly (by up to 25% based on the current Belgian withholding tax rate). On top, we expect that the
Automatic exchange of information of advance cross-border tax rulings from 1 January 2017
On 6 October 2015, the EU Finance Ministers reached political agreement in the Council to amend the existing Directive 2011/16/EU on administrative cooperation in the field of taxation (“the Directive”). The Directive will require the Member States to automatically exchange a basic set of information on advance cross-border tax rulings (“rulings”) and advance pricing arrangements
OECD recommendations on BEPS proposals for G20 and wider take-up
On 5 October 2015, multinational enterprises (“MNEs”) received final recommendations from the OECD’s base erosion and profit shifting (“BEPS”) project. This week, the G20 Finance Ministers are likely to agree on these OECD recommended changes to the international tax rules and to implementation plans. A number of non-G20 countries have also been involved in work
Global Tax Accounting Services Newsletter (July – September 2015)
The newsletter is to help multinationals stay aware of tax accounting and regulatory developments under US GAAP and IFRS, whilst providing technical guidance on challenging tax accounting areas.
