Belgian Council of Ministers approves Multilateral Agreement on Exchange of CbCR
Today, 24 February 2017, the Belgian Council of Ministers has agreed on a preliminary draft of the law approving the Multilateral Competent Authority Agreement on the exchange of Country-by-Country (CbCR) reports. On 27 January 2016, Belgium had signed this Agreement in Paris in the framework of the OECD BEPS (“Base Erosion and Profit Shifting”) Action
Likelihood of US Tax Reform reaches new high
The results of the US elections in November caught many by surprise with unexpected outcomes. Few predicted Republican candidate Donald J. Trump would be elected to serve as the next President. Republicans also retained majorities in both the US Senate and US House of Representatives. Expectations were for a split government for another 4 years
Belgian Minister of Finance sheds light on implementation of BEPS related measures
The Belgian Minister of Finance has just shared new insights on how Belgium will be addressing the outcome of the OECD/G20 project in relation to Base Erosion and Profit Shifting (“BEPS”). He opted to do so via the “Plan to combat tax fraud”. The title of his policy note is misleading since the document covers,
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
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
OECD releases model documents for implementing BEPS country-by-country reporting
On 8 June 2015, the OECD released a “Country-by-Country Reporting Implementation Package”. The package includes model legislation the OECD suggests could be used by countries to mandate filing of country-by-country reports (“CbCRs”). The model legislation does not attempt to address the filing of the so-called master file or local file reports. The key takeaway is
