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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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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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July 2018

25 Jul - United States: IRS updates country-by-country reporting guidance, information

24 Jul - Australia: Proposal to expand “significant global entity” definition, aligning country-by-country reporting with OECD model requirements

24 Jul - Belgium: Civil penalties for transfer pricing documentation compliance failures

23 Jul - OECD: Annual report on status of BEPS Inclusive Framework

18 Jul - Netherlands: Implications of Dutch transfer pricing decree on OECD discussion draft on transfer pricing of financial transactions

13 Jul - Nigeria: Country-by-country reporting guidelines

12 Jul - France: Transfer pricing documentation requirements, clarified and detailed

11 Jul - Luxembourg: Bill to ratify multilateral instrument (MLI) into domestic law

11 Jul - KPMG report: Initial impressions of OECD discussion draft on transfer pricing for financial transactions

10 Jul - Curaçao: Legislation implementing BEPS recommendations includes transfer pricing reporting obligations

6 Jul - France: Update on multilateral instrument (MLI) ratification

6 Jul - New Zealand: New BEPS law enacted, includes transfer pricing measures

5 Jul - Hong Kong: Passage of transfer pricing legislation (BEPS bill); most provisions effective from assessment year 2018/2019

5 Jul - India: Guidance on confidentiality, appropriate use of country-by-country reports

3 Jul - Nigeria: Transfer pricing update, including country-by-country reporting

3 Jul - OECD: BEPS discussion draft, transfer pricing aspects of financial transactions

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

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

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