US: IRS proposes to withdraw section 385 documentation regulations
On 21 September 2018, IRS published a document proposing to remove Section 385 from treasury regulation that was finalized in the last of the 2016. The regulations require multinationals that issue related-party debt to provide information to the
See MoreUK: Date of autumn budget 2018 announced
The UK has announced that the autumn budget proposals will be announced on 29 October 2018. The date is earlier than in previous years and appears to have been moved forward to avoid coinciding with important talks on Brexit that take place in
See MoreMultilateral Convention (MLI) signed by Saudi Arabia
Saudi Arabia signed the Multilateral Convention on 18 September 2018 to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI) bringing the total number
See MoreAustralia: ATO publishes Diverted profits tax guidance
The Australian Tax Office (ATO) published the final form of the Practical Compliance Guideline (PCG) 2018/5 Diverted profits tax (DPT) and Law Companion Ruling (LCR) 2018/6 Diverted profits tax. The PCG aims to assist affected clients and their
See MoreUS: IRS issues reminders relating to Form 8975 of CbC reporting
On 18 September 2018, IRS published a release reminding MNE groups on the processes of filing country-by-country reports on Form 8975. Reminder to U.S. MNEs Filing Form 8975 with no U.S. Schedule A (Form 8975) When submitting Form 8975 and Schedules
See MoreNetherlands: Budget Proposals 2019
On 18 September 2018, the government of Netherlands presented the 2019 budget proposals to the House of Representatives. Implementation of ATAD measures The Proposals put forward legislation that introduces various EU Anti-Tax Avoidance Directive
See MoreSpain issues amending CIT return and CbC reporting forms
On 14 September 2018, Spain published Order HAC/941/2018 of 5 September 2018 in the Official Gazette. Orders modified the regulate Form 202 (split payment of Corporation Tax and Income Tax for Non-Residents permanent establishments
See MoreNigeria: FIRS publishes a public notice regarding CbC Regulations
The Federal Inland Revenue Service (FIRS) issued a public notice on September 17, 2018. This notice provides alert that income tax country-by-country (CbC) reporting regulations S.I. no. 6, 2018 entered into force with effective from January 1, 2018
See MoreIMF report looks at Chile’s economy and tax reforms
On 20 September 2018 the IMF issued a report on the economic position of Chile following consultations under Article IV of the IMF’s articles of agreement. Chile has experienced strong economic growth in 2018 and is expected to reach around 4%
See MoreEU: Tax Rulings Issued by Luxembourg were not State Aid
On 19 September 2018 the European Commission determined that the non-taxation of certain profits arising to McDonald's Europe Franchising in Luxembourg did not amount to illegal State aid. The Commission had investigated under EU State aid rules
See MoreOECD: Effective Carbon Rates 2018
On 18 September 2018 the OECD issued the publication Effective Carbon Rates 2018: Pricing Carbon Emissions through Taxes and Emissions Trading. The report presents date on taxes and tradeable permits for carbon emissions in 42 countries from the
See MoreOECD: Comments published on discussion draft on transfer pricing for financial transactions
On 18 September 2018 the OECD published comments received on its discussion draft on financial transactions in relation to BEPS actions 8 to 10 (ensuring that transfer pricing outcomes are in line with value creation). Discussion draft The
See MorePeru: Added new thin Capitalization Rules and Amended Income Tax Law
Peru’s President enacted Legislative Decree 1424 on 13 September 2018, which amends the income tax law with regard to the thin capitalization rules, the indirect transfer of shares, the definition of permanent establishment (PE) and the indirect
See MorePoland updates TP reporting regime
The Polish Ministry of Finance has announced on the e-Deklaracje website interactive forms to be used as transfer pricing (TP) reports. Beginning 1 January 2017, taxpayers that transacted or engaged in other operations with related parties of a
See MoreOECD: Inclusive Framework issues further guidance on CbC reporting
On 13 September 2018 the OECD’s Inclusive Framework released additional interpretative guidance in relation to Country-by-Country (CbC) reporting under Action 13 of the OECD/G20 report on base erosion and profit shifting (BEPS). More than 100
See MoreIsrael and Lithuania both complete ratification of BEPS MLI
Israel and Lithuania have ratified a multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). This means that both countries have completed the domestic process and deposit its ratification instrument for MLI. This
See MoreIMF report looks at UK economy
On 17 September 2018 the IMF issued a report following discussions with the UK under Article IV of the IMF’s articles of agreement. Economic growth in the UK has decreased since the EU referendum in June 2016 owing to uncertainty in relation to
See MoreOECD: Tax Policy Reforms 2018
On 14 September 2018 the OECD issued Tax Policy Reforms 2018, summarizing the tax policy reforms carried out in the year by OECD countries and by Argentina, Indonesia and South Africa. Corporate income tax The report notes that significant tax
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