2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations
On 10 July 2017, the Organisation for Economic Cooperation and Development (OECD) announced that it released the 2017 edition of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TPG). The 2017 edition is a consolidated version of the various changes resulting from the OECD/G20 BEPS Project. In this respect, in particular the following
EU Parliament adopts resolution on public CbCR
In the fight to crack down on corporate tax avoidance, the European Parliament has voted in plenary that multinational companies should disclose tax information in each country they operate. Consequently, multinationals with a worldwide turnover of minimum EUR 750 million should publicly disclose how much tax they pay and where, including taxes paid outside the EU. Large firms
European Parliament Committees approve public Country-by-Country Reporting proposal
Further to the work of the OECD in the framework of the BEPS project, the European Parliament’s Economic and Monetary Affairs and Legal Affairs (ECON/JURI) committee members adopted on Monday 12 June 2017 their joint report on the EU Commission’s draft public CbCR Directive (The consolidated committee report is not yet published, but should be
Agreement on new council directive on double taxation dispute resolution
During its meeting on 23 May 2017, the ECOFIN Council reached an agreement on a proposal for a new system for resolving double taxation disputes within the EU. Based on the Convention on the elimination of double taxation in connection with the adjustment of profits of associated enterprises (the EU Arbitration Convention – 90/436/EEC), the
OECD releases discussion draft on the implementation guidance on hard-to-value intangibles
On 23 May 2017, the OECD released (under the impetus of the Final Report on BEPS Actions 8-10) a discussion draft which aims to giving guidance on the implementation of the approach to use ex post results as presumptive evidence about the ex ante pricing of transfers of hard-to-value intangibles (“HTVI”). The approach is described
OECD publishes additional guidance on Country-by-Country reporting (BEPS Action 13)
On 6 April 2017, the OECD has published further guidance for tax administrations and MNE Groups on Country-by-Country (CbC) reporting (Base Erosion and Profit Shifting (BEPS) Action 13). The guidance was released by the Inclusive Framework, which brings together over 100 countries and jurisdictions to collaborate on the implementation of the OECD/G20 BEPS Package. The
Belgian Council of Ministers approves Multilateral Agreement on Exchange of Financial Account Information
Yesterday, 23 February 2017, the Belgian Council of Ministers approved a draft bill which implements the multilateral competent authority agreement on the automatic exchange of financial account information (“the Agreement”) that was developed by the OECD and the G-20 countries and published in 2014. On 29 October 2014, Belgium had, together with 50 other jurisdictions,
OECD releases peer review documents for assessment of BEPS minimum standards
On 1 February, the OECD released key documents which will form the basis of the peer review of the Action 5 transparency framework and for the peer review of Action 13 Country-by-Country Reporting. The Action 5 standard for the compulsory spontaneous exchange of information on tax rulings (the “transparency framework”) and the Action 13 standard on Country-by-Country Reporting
