News articles written by Axel Smits

European Commission explains State aid investigations in Ireland and Luxembourg

1 October 2014

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

26 September 2014

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

26 September 2014

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

18 September 2014

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

16 September 2014

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