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
Brexit and IFRS Tax Accounting
A little over nine months after British voters chose to withdraw from the EU, Britain took a decisive, and likely irreversible, step on Wednesday 29 March 2017 by giving formal notice of its intention to leave the EU. This notice will trigger the process of negotiating the UK’s exit, which is likely to last at
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,
CJEU rules on subject-to-tax requirement of Parent-Subsidiary Directive
On 8 March 2017, the Court of Justice of the European Union (“CJEU”) rendered its Judgment in Wereldhave Belgium and Others concerning the interpretation of the subject-to-tax requirement of the Parent-Subsidiary Directive (“PSD”) (C-448/15). The CJEU’s interpretation of the PSD’s subject-to-tax requirement is more severe than a mere formal subjective tax liability. However, the precise
UK introduces new corporation tax limitation on interest deductibility
The draft UK Finance Bill 2017 was published in early December 2016. The Bill contains detailed draft legislation to introduce a new limitation on the deductibility of interest expense from corporate profits. These rules, which were further amended on January 26, 2017, will apply to amounts accruing after April 1, 2017. The rules limit a
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
Council agrees its position on hybrid mismatches with third countries
On 21 February 2017, the Council of the EU, meeting through its Economic and Financial Affairs (ECOFIN) Council, agreed its position on rules aimed at closing down ‘hybrid mismatches’ with the tax systems of third countries (so called ATAD II). Following to the European Commission’s proposal on amendments to the Anti-Tax Avoidance Directive (ATAD) as
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
