UK’s ‘Diverted Profits Tax’ proposes a 25% tax rate for taxpayers but leaves open questions
Background On 10 December 2014 HM Revenue & Customs (HMRC) released the diverted profits tax (DPT) provisions within its draft Finance Bill 2015. Upon initial review, the new rules could affect many more companies than one might have anticipated. Scope The DPT is a new tax, with a 25% rate on profits that are considered
European Commission explains State aid investigations in Ireland and Luxembourg
On 30 September 2014 the European Commission published its opening decisions in the formal investigations into transfer pricing agreements between Apple and, allegedly, Fiat and – respectively – Ireland and Luxembourg. The European Commission had already communicated these investigations through a press release issued on 11 June 2014. The current decisions explain the reason for
OECD Report on Action 6 – Treaty Abuse
The OECD published a discussion draft in March 2014 on proposals for addressing perceived abuse of tax treaties. The draft recommended extensive changes to the OECD Model Treaty together with suggested domestic law provisions targeted at treaty abuse or abuse of domestic law where the abuse involves application of treaty benefits. It also proposed a
OECD finalises guidance on transfer pricing documentation and country-by-country reporting
On 16 September 2014, the Organisation for Economic Cooperation and Development (OECD) finalized its guidance in relation to transfer pricing documentation and country-by-country (CbC) reporting. The final report is broadly consistent with the Discussion Draft released by the OECD on 30 January 2014, although it has pared back some proposals in response to concerns of
OECD recommendations on BEPS 2014 deliverables: Few surprises, but no let-up
As indicated in a newspost earlier this week, the BEPS deliverables for the September 2014 deadline have been published on 16 September 2014 and are available on the OECD website. Please find herewith a link to a summary PwC Bulletin in this respect, highlighting the key take-aways of the reports.
OECD releases BEPS reports following September deadline
The OECD is keeping its word in preparing and delivering on the objectives as they have been set in the BEPS Action Plan. The deliverables for the September 2014 deadline have just been published and are available on the OECD website (link below). The OECD has published 7 reports (Digital Economy, Hybrid Mismatches, Harmful Tax, Treaty Abuse, Intangibles
Upcoming Global OECD BEPS webcasts
In the framework of the upcoming G20 Finance Ministers meeting to be held in Cairns, Australia on 20-21 September 2014, there are two global OECD BEPS webcasts scheduled this month for you in order to guide you through and anticipate on any potential impact on your businesses: BEPS: Global alignment vs national interest?: This first is a live
OECD releases request for input on BEPS Action 11
Background The Action 11 work of the BEPS (base erosion and profit shifting) action plan aims to produce an overview of several different economic analyses of BEPS using different data and methodologies that will give a potential range of the scale (i.e. magnitude of the change in overall tax receipts) and economic impacts (i.e. effects on total
