KPMG’s Week in Tax: 4 - 8 September 2017 - KPMG Luxembourg
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KPMG’s Week in Tax: 4 - 8 September 2017

KPMG’s Week in Tax: 4 - 8 September 2017

Tax developments or tax-related items reported this week include the following.


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Transfer Pricing and BEPS

  • OECD: New guidance on the implementation and operation of country-by-country (CbC) reporting under Action 13 of the base erosion and profit shifting (BEPS) project addresses: (1) the definition of revenues; (2) the treatment of multinational entity groups with a short accounting period; and (3) the treatment of the amount of income tax accrued and income tax paid.
  • Denmark: The Danish tax authorities published an annual report of transfer pricing statistics, trends, and forecast that reveals an all-time record of downward income adjustments.

Read TaxNewsFlash-Transfer Pricing


  • Ireland: The deadline for companies to disclose beneficial ownership information to a central register has been extended to November 2017.
  • Cyprus: Changes have been made to the value added tax (VAT) appeal procedure, effective as of 7 July 2017.
  • Germany: Laws enacted include an “anti-patent box law,” and new regulations concern the rules for documenting profit allocations—generally in line with the recommendations under the OECD’s base erosion and profit shifting (BEPS) project.
  • Romania: New measures in Romania’s tax law, generally effective 1 January 2018, include corporate and individual income tax provisions relating to the taxation of foreign representative offices and income derived from “independent activities.”

Read TaxNewsFlash-Europe

Asia Pacific

  • Australia: “Super guarantee gap” reforms would allow the Australian Taxation Office to identify patterns and potential non-compliance earlier and would provide a greater focus for its reviews.
  • Thailand: The customs authorities have terminated a voluntary audit program and will focus on preparing for the introduction of a new customs law that will be effective 13 November 2017.
  • Thailand: A foreign company’s representative office in Thailand is no longer required to obtain a foreign business license, but is still subject to other Thai legal and tax compliance rules—including a requirement to file required tax returns in Thailand.

Read TaxNewsFlash-Asia Pacific


  • Mauritius: Individuals who have income exceeding MUR 15 million or more or who own assets with a value exceeding MUR 50 million must submit a statement of assets and liabilities with their income tax returns by 2 October 2017 for the income year ended 30 June 2017.

Read TaxNewsFlash-Africa


  • Cayman Islands: The automatic exchange of information (AEOI) Portal will be open until 13 September 2017 to accept late registrations, variations, and reporting and filing declarations prior to the preparation of data for transmission.
  • Hong Kong: The automatic exchange of information (AEOI) guidance has been updated for financial institutions with respect to the common reporting standard (CRS) regime.
  • Singapore: Reporting financial institutions can now submit an application for CRS registration via the CRS registration e-service.
  • Vietnam: Guidance to financial institutions concerns FATCA implementation in Vietnam in accordance with the intergovernmental agreement (IGA) between Vietnam and the United States.
  • OECD: Greenland, Cambodia, Madagascar, and Haiti joined a global forum on transparency with respect to the AEOI.

Read TaxNewsFlash-FATCA / IGA / CRS

United States

  • The IRS issued Rev. Proc. 2017-47 to provide a safe harbor for public utilities that inadvertently or unintentionally use a practice or a procedure that is not consistent with the Code’s “normalization rules” concerning the investment tax credit and/or accelerated depreciation.
  • The Supreme Court of Virginia issued a decision in a case addressing the application of the “subject to tax” exception under Virginia’s related-party addback statute when royalties are paid by the taxpayer to an affiliate. The court held that the “subject to tax” exception applies on a post-apportionment basis, provided that the royalties are actually taxed by another state.
  • The IRS announced that because of hurricane-related shortages of fuel, relief from penalties for sales of dyed diesel fuel for use on the highway was being expanded for the entire State of Texas. The effective date for this relief is 25 August 2017, through 15 September 2017.
  • An IRS notice provides guidance with respect to leave-based donation programs initiated by employers to aid their employees who were affected by Hurricane Harvey and Tropical Storm Harvey.

Read TaxNewsFlash-United States


  • President Trump in a speech called for a territorial system of taxation and said that passing tax cuts and tax reform would give the United States a competitive edge in the global market and rebuild the economy and create more jobs.
  • Congress returned to Washington this week to two looming deadlines: (1) action must be taken to increase the debt limit soon (perhaps before the end of September) to avoid a government default; and (2) government funding expires at the end of September (i.e., the end of the 2017 fiscal year). Major tax legislation is also a topic of intense interest for congressional Republicans.

Read TaxNewsFlash-Tax Reform

Trade & Customs

  • U.S. Customs and Border Protection announced guidelines for cargo entries affected by Hurricane Irma and Hurricane Harvey.
  • A notice from the Bureau of Industry and Security (BIS) of the U.S. Commerce Department requests comments about the existing foreign policy-based export controls within the Export Administration Regulations (EAR).

Read TaxNewsFlash-Trade & Customs

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