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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

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

Taxation of the Digitalized Economy

KPMG's reports of developments concerning the tax treatment of the digital economy, including digital services tax and the taxation of online, remote sales

>> Read more

 

September - October 2016

31 Oct - OECD: Reminder about business survey on tax certainty 16 December cutoff

31 Oct - OECD: BEPS Action 14, peer reviews schedule

28 Oct - Hong Kong: Consultation on formal transfer pricing regime

28 Oct - OECD: Automatic exchange of tax information agreement, signed by Cook Islands

27 Oct - OECD: Panama signs agreement for automatic exchange of tax information

25 Oct - Channel Islands: Country-by-country reporting, draft regulations in Jersey

24 Oct - Singapore: Country-by-country reporting guide

21 Oct - Ireland: Irish Revenue updates FAQs on country-by-country reporting

21 Oct - Cyprus: Amendments to intellectual property tax regime, implementing BEPS recommendations

21 Oct - OECD: Five jurisdictions agree to automatic exchange of country-by-country reports

21 Oct - Vietnam: Draft decree to implement transfer pricing standards, BEPS recommendations

20 Oct - OECD: MAP peer review, for resolving treaty-related disputes (BEPS Action 14)

19 Oct - OECD: Andorra joins BEPS inclusive framework

14 Oct - IRS legal advice memo: Legal responsibilities to protect return information, under OECD’s transmission system

14 Oct - UK: Practical issues that businesses may face concerning country-by-country reporting

13 Oct - Australia: Involving human resources, mobility professionals in country-by-country reporting

10 Oct - France: Decree implementing country-by-country reporting

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

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