Political agreement on fundamental overhaul of the international tax system
On 8 October 2021, the Inclusive Framework (IF) announced a further agreement backed by 136 (out of 140) members of the Inclusive Framework on the two-pillar approach. In the last few days, a number of countries that initially opposed the reform are now also signing up for it (e.g. Hungary, Ireland and Estonia). With this,
Country-by-country reporting goes public!
On 1 June 2021, representatives of the European Parliament and the Council under EU Portuguese Presidency negotiated a Draft Directive on public country-by-country reporting (‘Public CbCR’) for big multinational groups. They provisionally reached a compromise agreement. Once this political agreement is endorsed, it requires European or non-European multinational groups or standalone undertakings to publicly disclose
The OECD published its blueprints on pillar 1 and 2 – get the latest insights via our webcast.
The OECD released ‘Blueprints’ on the tax digitalisation/globalisation project on Monday 12 October. These two Blueprints cover Pillar 1 and Pillar 2 in the project framework previously announced. Pillar 1 looks at the attribution of revenues to market jurisdictions. Pillar 2 deals with the imposition of a minimum tax. The Blueprints indicate the degree of
OECD releases the draft contents of the 2017 update to the OECD Model Tax Convention
The OECD announced that earlier this week, on 11 July 2017, the OECD Committee on Fiscal Affairs released the draft contents of the 2017 update to the OECD Model Tax Convention (‘MTC’) prepared by the Committee’s Working Party 1. The draft contents of the 2017 update to the OECD MTC has not yet been approved by
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
Brazil: Changes to calculation basis of net equity payments and to withholding tax on interest
Here’s a link to a Tax Newsalert with respect to Brazil Taxation you may find very interesting – link This ITS Newsalert reports on Provisional Measure 694/2015, which changes the calculation basis of, and the withholding tax rates applicable to interest on, net equity payments in Brazil. Should you have any further questions on this topic
UK’s ‘Diverted Profits Tax’ proposes a 25% tax rate for taxpayers but leaves open questions
Background On 10 December 2014 HM Revenue & Customs (HMRC) released the diverted profits tax (DPT) provisions within its draft Finance Bill 2015. Upon initial review, the new rules could affect many more companies than one might have anticipated. Scope The DPT is a new tax, with a 25% rate on profits that are considered
BEPS Project: Time to take a closer look at treasury and intercompany financing
OECD Base Erosion & Profit Shifting (BEPS) Project: Time to take a closer look at treasury and intercompany financing Just before the New Year’s break, the OECD issued new discussion drafts in the context of the so-called ‘Base Erosion & Profit Shifting’ project as mandated by the G20, better known as ‘BEPS’. They are particularly
