EU Commission Opens to Cross-Border Tax Rules | KPMG | CA
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EU Commission Opens Its Windows on Cross-Border Tax Rulings

EU Commission Opens to Cross-Border Tax Rules

The European Commission released draft legislation requiring EU countries to share their cross-border tax rulings information on a quarterly basis.


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The European Commission recently released draft legislation requiring EU countries to share information on all of their cross-border tax rulings on a quarterly basis, including advance pricing agreements (APA). If approved, the new automatic exchange rules would enter into force as of January 1, 2016 and would apply for all rulings granted over the past 10 years, if they are still in force.

Specifically, the shared information must include:

  • The taxpayer's name
  • The group to which the taxpayer belongs
  • A list of other taxpayers and EU countries possibly affected by the ruling or APA
  • The content of the ruling or APA
  • The criteria used for the transfer price in the case of an APA.

Among other measures, proposals include repealing the EU Savings Directive and possibly extending the country-by-country reporting by companies in all sectors. The country-by-country reporting measure being considered would involve public disclosure that is in line with the EU rules for banks and the extractive industry.

For more information, contact your KPMG adviser.


Information is current to March 24, 2015. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation.

For more information, contact KPMG's National Tax Centre at 416.777.8500

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