KPMG’s Week in Tax: 12-16 October

KPMG’s Week in Tax: 12-16 October

Now that the G20 finance ministers have approved the OECD’s final recommendations under the base erosion and profit shifting (BEPS) project, certain countries have taken actions for local implementation of the BEPS recommendations, even before the G20 country leaders consider the final recommendations at their November 2015 summit in Turkey.

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For instance, countries expected to or that have implemented country-by-country (CbC) reporting and other transfer pricing disclosure requirements based on Action 13 of the BEPS project include:

  • France: An announcement states draft legislation to implement CbC reporting will be before year-end. 
  • UK: HMRC initiated a technical consultation on CbC reporting, and proposals for a legislative requirement for large businesses to publish their tax strategy as it relates to or affects UK taxation.
  • Denmark: A legislative proposal includes measures that would enhance the Danish transfer pricing documentation requirements and include CbC reporting. 
  • Australia: A CbC bill was introduced as part of a larger package of legislation that includes CbC, master file, and local file requirements consistent with BEPS Action 13. 
  • Netherlands: The tax plan for 2016 includes CbC reporting and more stringent documentation requirements under the form of a master file and a local file, in line with the OECD model. 
  • Poland: The lower house passed a bill containing amendments to the tax laws, including changes to the transfer pricing rules and introducing CbC reporting, local, and master file requirements. 
  • Mexico: Proposals would expand the transfer pricing documentation requirements under the form of a master file and a local file, and introduce CbC reporting. 
  • South Korea: Draft legislation would require taxpayers, subject to the Korean transfer pricing rules, to submit both a master file and a local file containing information on related-party transactions. 
  • Spain: Multinational corporations, foreign-owned Spanish subsidiaries, and permanent establishments would be subject to stricter reporting requirements.
  • Switzerland: The Swiss Federal Council gave the Swiss delegation to the OECD the “go ahead” to accept the final BEPS reports.
  • Norway: The budget for 2016 contains proposals for CbC reporting.
  • United States: The Treasury Secretary formally accepted the deliverables from the G-20/OECD BEPS project concerning international rules governing the taxation of company profits.

Read TaxNewsFlash-BEPS

Other tax news

  • Ireland: Budget 2016 was announced, and details concerning a tax incentive known as the “knowledge development box” were provided in the budget statement.
  • Poland: Legislation to support innovation—by amending the corporate income tax and providing new tax relief for R&D as well as other measures—was passed by the Senate, thus clearing the way for the bill to be sent for action by the president.
  • Belgium: The government announced that it reached an agreement on the budgets 2015 and 2016 and on the implementation of the “tax shift.”

Read TaxNewsFlash-Europe

 

  • Angola: A legislative decree amends the rates applicable for the consumption tax and for customs duties on imports.
  • Zambia: The budget for 2016 was presented.

Read TaxNewsFlash-Africa

 

  • Dominican Republic: The tax authority extended the time for taxpayers in the agricultural sector to seek tax exemptions or other tax benefits.

Read TaxNewsFlash-Americas

 

  • United States: An advanced version of IRS Notice 2015-72 includes text of a “proposed revenue procedure” that would be issued to update existing IRS guidance with respect to the administrative appeals process for cases docketed in the U.S. Tax Court—“docketed cases”—and coordination between IRS Appeals and Chief Council offices.

Read TaxNewsFlash-United States

FATCA developments

  • Hong Kong: Legislative proposals will be amended to implement the international standard on “automatic exchange of financial account information” (AEOI) in tax matters.

Read TaxNewsFlash-FATCA

 

Read these and other items reported this week at the TaxNewsFlash United States and Global websites.

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