News articles written by Patrick Boone

Automatic exchange of information of advance cross-border tax rulings from 1 January 2017

7 October 2015

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

7 October 2015

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

19 June 2015

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

OECD publishes Discussion Draft on cost contribution arrangements

4 May 2015

On 29 April 2015, the OECD issued a Discussion Draft on the transfer pricing aspects of cost contribution arrangements (‘CCAs’) under Action 8 of the BEPS action plan. The Draft proposes fundamental modifications to Chapter VIII of the OECD Transfer Pricing Guidelines: With respect to measuring the value of contributions to CCAs and the tax