OECD publishes (long awaited) additional guidance on hard-to-value intangibles and profit split methods
In view of landing on the Transfer Pricing track in its work to curb Base Erosion and Profit Shifting (BEPS Actions 8-10) the OECD published two new reports on 21 June 2018: Guidance for tax administrations on the application of the approach to hard-to-value intangibles; and Revised guidance on the application of the profit split
As per our previous update, the ECOFIN Council formally adopted – on 25 May 2018 – the directive on mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements – also known as DAC6. As the directive will already enter into force in the next weeks and will have an
On 26 July 2017, the federal government reached an agreement on an important tax, economic and social reform package. A significant gradual reduction in the corporate income tax rate to 25% in 2020 and fiscal consolidation are key components of the package. The agreement preserves the notional interest deduction. The tax reform is built around
Remark: The following announced measures will have to be formalised in draft legislation which should only be available as from September/October. Only then will full details be known. On 26 July 2017, the Federal government reached an agreement on an important corporate tax reform, significantly reducing the corporate tax rate. More details will follow below.