OECD Published Guidance on Amount B
On 19 February 2024, the OECD published a report which aims to simplify and streamline the application of the arm’s length principle to in-country baseline marketing and distribution activities (the Report) (also known as Amount B under Pillar One). The first draft guidance and call for input dates back from late 2020. Quite some time
Public Country-by-Country Reporting adopted
Introduction On 11 November 2021, the European Parliament adopted the Directive on public country-by-country reporting (PCbCR). The adoption of this directive concludes the procedure (see earlier newsflash) on the introduction of specific European transparency rules and requires certain European or non-European multinational groups or standalone undertakings to publicly disclose certain financial data. Content of the
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,
OECD Inclusive Framework agrees on two-pillar Approach for International Tax Framework
On 1 July 2021, the Inclusive Framework (IF) announced an agreement backed by 130 (out of 139) members of the Inclusive Framework on the two-pillar approach. This approach redesigns the international tax framework. Here’s a summary of the main points of the agreement: Pillar one Pillar One is intended to re-allocate the taxing rights of
G7 commits to a global minimum tax of at least 15% and taxation of digitalised economy
The G7 finance ministers published on 5 June 2021 a Communiqué announcing that they reached a high-level political agreement on a global tax reform. In particular, they agreed on the reallocation of a share of the profits of certain multinational enterprises to market jurisdictions (Pillar 1) and a global minimum tax of at least 15%
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
Tax Bites Podcast: How do you keep the effect of COVID at arm’s length?
In the final days of 2020, the OECD released guidelines on the implications of the COVID-19 pandemic on transfer pricing. Pieter Deré, is joined by our transfer pricing experts, Jonas Van de Gucht, Stefaan De Baets and Alexis De Méyère. They will discuss the impact of the OECD transfer pricing guidelines on multinationals’ transfer pricing
Publication of updated FAQs on Belgian documentation requirements
On 30 June 2020, the Belgian Tax Authorities published its Circular Letter 2020/C/88 containing an update of the Frequently Asked Questions (FAQ) (previous version dd. 4 May 2018) with respect to the Belgian transfer pricing documentation requirements on Country-by-Country Reporting (CbCR) (articles 321/1 to 321/2 BITC), the notification on CbCR (article 321/3 BITC), the Master
