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BEPS

BEPS

TaxNewsFlash-BEPS — KPMG's reports of developments of interest to multinationals on the OECD's base erosion and profit shifting (BEPS) initiative and tax transparency.

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TaxNewsFlash-BEPS

TaxNewsFlash-BEPS

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BEPS Action 13: Latest country implementation update

Updated weekly, this summary report in table format offers a snapshot of implementation of country-by-country (CbC) reporting and Master file / Local file documentation requirements around the world.

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March 2018

30 Mar - United States: IRS guidance on country-by-country reporting by “specified national security contractors”

26 Mar - Argentina: Country-by-country notification deadline extended to 2 May 2018

23 Mar - UK: Voluntary preparation of Master file, Local file documentation; UK-parented multinational entities

23 Mar - OECD: Multilateral BEPS convention (MLI) entry into force 1 July 2018 (Slovenia, Austria, Isle of Man, Jersey, Poland)

22 Mar - EU: Guidelines from European Commission, avoid channeling EU funds through non-cooperative tax jurisdictions (EU “blacklist”)

22 Mar - OECD: Additional guidance on attribution of profits to permanent establishments (BEPS Action 7)

21 Mar - EU: Proposals for taxation of digital businesses

20 Mar - Nigeria: Country-by-country reporting to be added to transfer pricing rules

20 Mar - Netherlands: Update about multilateral instrument (MLI)

16 Mar - OECD: Interim report, tax challenges from digitalisation (BEPS)

16 Mar - Poland: Extended deadline for transfer pricing documentation requirements

16 Mar - India: Lower house passes Finance Bill 2018; changes to country-by-country reporting, Master file rules

13 Mar - EU: Disclosure rules, reportable cross-border arrangements by tax advisers

12 Mar - OECD: Improving tax dispute resolution mechanisms under BEPS Action 14, including MAP access

9 Mar - Australia: Hybrid mismatch arrangements (BEPS Action 2); revised draft legislation for public consultation

7 Mar - EU: Aggressive tax planning; focus on interest, royalties, transfer pricing

6 Mar - Mauritius: Country-by-country reporting regulations, effective July 2018

June 2017

30 Jun - United States: Form 8975 and instructions for country-by-country reporting; IRS launches CbC webpage

28 Jun - OECD: Update on international tax transparency

27 Jun - KPMG report: Discussion draft, BEPS Action 10 revised guidance on profit splits

23 Jun - KPMG reports: Effects of multilateral instrument implementing BEPS in various tax treaties

23 Jun - Romania: Country-by-country reporting added to tax law

22 Jun - OECD: BEPS inclusive framework, update on country-by-country reporting exchanges

22 Jun - OECD: BEPS discussion drafts, attribution of profits to permanent establishments and transactional profit splits

21 Jun - Canada: New exchange arrangement with United States, to implement country-by-country reporting standard

21 Jun - EU: Proposed mandatory disclosure of reportable tax planning cross-border arrangements

19 Jun - UK: Country-by-country reporting, notification to HM Revenue & Customs

16 Jun - Russia: Status of country-by-country reporting, transfer pricing documentation proposals

12 Jun - OECD: Botswana joins BEPS inclusive framework 

9 Jun - KPMG analysis: Multilateral instrument implementing the treaty-related BEPS provisions

9 Jun - OECD: Taxpayer input requested, third batch of BEPS “dispute resolution” peer reviews

8 Jun - KPMG reports: Initial impressions of multilateral instrument implementing BEPS in tax treaties

7 Jun - OECD: Countries sign multilateral instrument, implementing BEPS in tax treaties

6 Jun - OECD: Multilateral convention implementing BEPS recommendations into treaties; signing ceremony on 7 June 

6 Jun - Hungary: Country-by-country reporting approved by parliament

5 Jun - Colombia: Legislative measures implementing BEPS actions on CFCs, preferential tax regimes, VAT on cross-border services

2 Jun - Poland: Multilateral convention implementing BEPS; effects on Poland's tax treaties currently unknown

2 Jun - OECD: Thailand joins BEPS inclusive framework

October 2016

September 2016

29 Sep - Hong Kong: Incentives for intra-group financing activities, corporate treasury centres

28 Sep - Channel Islands: Country-by-country reporting, consultation in Guernsey

28 Sep - OECD: Public consultation on BEPS-related transfer pricing matters, 11-12 October

28 Sep - Sweden: Country-by-country reporting provisions in budget bill for 2017

27 Sep - Australia: Country-by-country reporting exemption guidance

23 Sep - OECD: Comments on “branch mismatch structures” under BEPS Action 2 

20 Sep - Denmark: New executive order on country-by-country reporting

16 Sep - Russia: Country-by-country reporting requirements, transfer pricing documentation

15 Sep - OECD: Comments on discussion draft, interest from banking and insurance under BEPS Action 4

13 Sep - United States: EC state aid investigations show need for tax reform

9 Sep - UK: Public country-by-country reporting, amendment to Finance Bill 2016 

8 Sep - New Zealand: Proposal, implementing BEPS Action 2 hybrid mismatch recommendations

7 Sep - OECD: Comments on BEPS discussion drafts—profit splits, profits attributed to permanent establishments

6 Sep - OECD: Status report on BEPS for G20 leaders

1 Sep - Brazil: Automatic exchange of country-by-country reports

August 2016

25 Aug - OECD: Initial analysis of discussion draft, branch mismatch structures

25 Aug - OECD: Public comments, group ratio rule under BEPS Action 4

24 Aug - U.S. Treasury “white paper” on EC’s state aid investigations of transfer pricing rulings

24 Aug - OECD: Comments on proposed amendments, OECD Transfer Pricing Guidelines

22 Aug - Liechtenstein: Automatic exchange of country-by-country reporting

22 Aug - OECD: Discussion draft, branch mismatch structures under BEPS Action 2

18 Aug - Czech Republic: Automatic exchange of APAs, country-by-country reporting proposals

16 Aug - Israel: Country-by-country reporting, transfer pricing documentation in budget plan

11 Aug - Nigeria: Country-by-country reporting, implementation moves forward

9 Aug - Canada: Discussion, observations about country-by-country reporting proposal

8 Aug - Asia Pacific: Country-by-country reporting, status update for region

8 Aug - EU: Country-by-country reporting—an EU perspective

5 Aug - Australia: Review of transfer pricing developments since 2012; plans for more BEPS changes

5 Aug - Luxembourg: Draft law for country-by-country reporting submitted to Parliament 

3 Aug - Canada: Country-by-country reporting requirements in draft legislative proposals

1 Aug - KPMG report: Discussion draft on approaches to address BEPS involving Interest in banking and insurance sectors

1 Aug - KPMG report: Indirect tax implications of BEPS project

1 Aug - Korea: Revised legislation, transfer pricing and country-by-country reporting rules

July 2016

28 Jul - OECD: Discussion draft, BEPS in banking and insurance sectors

25 Jul - Austria: New transfer pricing documentation, country-by-country rules effective for 2016

25 Jul - OECD: Report on status of BEPS project

18 Jul - OECD: Jamaica joins BEPS framework

14 Jul - Australia: Government's approach to key BEPS actions following the 2016 federal election

13 Jul - China: Transfer pricing documentation, related-party reporting guidance from BEPS project

12 Jul - OECD: BEPS status update

11 Jul - Hong Kong: BEPS participation, recommendations pending government action

11 Jul - OECD: Discussion draft, “group ratio rule” under BEPS Action 4

7 Jul - OECD: Discussion draft under BEPS Actions 8-10, profit split guidance 

7 Jul - OECD: Discussion draft under BEPS Action 7, profits attributed to
permanent establishments

6 Jul - Hong Kong: Transfer pricing and BEPS considerations—intangible property and R&D activities

5 Jul - Belgium: Country-by-country reporting, transfer pricing documentation; new law is published

4 Jul - Japan: Guidance under new transfer pricing documentation rules

4 Jul - OECD: BEPS discussion drafts include revised guidance on profit splits

4 Jul - OECD: Comments invited on revised transfer pricing guidelines

1 Jul - Germany: Country-by-country reporting, BEPS items in draft bill

June 2016

30 Jun - OECD: New inclusive framework, 80+ countries at BEPS meeting

29 Jun - United States: Initial description of country-by-country reporting final regulations

29 Jun - OECD: Guidance on implementation of country-by-country reporting

29 Jun - United States: Country-by-country reporting, final regulations (text)

28 Jun - New Zealand: Recommendations for foreign trusts, inbound investment, BEPS proposals

28 Jun - OECD: Offshore tax evasion convention signed by Dominican Republic, Nauru

24 Jun - Singapore: Country-by-country reporting

21 Jun - EU: Agreement on directive reached, new tax avoidance rules

20 Jun - Finland: Transfer pricing documentation, country-by-country reporting draft legislation

16 Jun - OECD: Webcast discussions about BEPS, tax transparency

15 Jun - OECD: BEPS amendments incorporated into Transfer Pricing Guidelines

7 Jun - EU: Council approves country-by-country reporting, mandatory automatic exchanges of tax information 

2 Jun - KPMG’s initial analysis of OECD discussion draft: Development of multilateral instrument

2 Jun - OECD: Jamaica, Uruguay sign tax-assistance convention, Brazil completes ratification

1 Jun - OECD: Multilateral instrument to implement tax treaty-related BEPS measures, request for comments

May 2016

25 May - Australia: Country-by-country, final Local files released

25 May - Norway: Transfer pricing documentation, country-by-country reporting included in political agreement

23 May - Netherlands: Proposed “innovation box” changes, align with BEPS recommendations

23 May - US: Senators again express concerns about EC state-aid investigations

20 May - China: Participation in global tax initiatives (BEPS, CRS)

19 May - Denmark: New transfer pricing documentation requirements

19 May - Austria: Proposed legislation, transfer pricing documentation and country-by-country reporting

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