BEPS

News & Analysis as of

Anti-BEPS Ukraine style: de-offshorization initiative launches

Leakage of profits to offshore locations and tax evasion through aggressive planning has always been a hot topic in Ukraine. However, it must be said that, with the exception of the introduction of transfer pricing rules in...more

OECD BEPS Working Groups issue three discussion drafts

The Committee of Fiscal Affairs of the Organization of Economic Cooperation and Development (OECD) has released three documents: its proposed updated guidelines on the application of the transactional profit split, draft...more

Further down the rabbit hole we go: Additional guidance released by OECD on the attribution of profits to permanent establishments

Action 7 of the BEPS Action Plan1 tackles the definition of permanent establishment (PE) in order to prevent the artificial avoidance of a PE status through the use of commissionaire arrangements and the specific activity...more

China makes major changes to transfer pricing documentation and country-by-country reporting requirements

China’s State Administration of Taxation (SAT) on 13 July released on its website guidance that makes substantial changes that apply to multinationals’ transfer pricing compliance obligations for the 2016 fiscal year....more

UK Government Confirms Introduction of New Cap on Interest Deductibility

The UK Government has recently confirmed that it will be introducing a new cap on interest deductibility. Under the new rule, the ability of groups to obtain tax relief for interest will be limited by reference to a ratio of...more

Dentons Global Energy Summit 2016 Analysis

On 17 May 2016, Dentons' third annual Global Energy Summit brought together key industry leaders to discuss current challenges facing the energy sector and the opportunities arising from them. Over 200 delegates and 50...more

Brexit Update: What’s Next for the Global Marketplace

In Depth - UK Withdrawal Process - The United Kingdom will continue to be an EU member until procedures are completed for exiting the European Union, which is likely to be a long process. Under EU Treaty rules,...more

Five key elements of the EU ATA Directive compromise

In late June, the Economic and Financial Affairs Council of the European Union (ECOFIN or the Council) achieved political consensus on the content of the EU Anti-Tax-Avoidance Directive (the ATA Directive). In last month's...more

Brexit: What are the implications for tax law?

The precise impact of a Brexit on UK tax law is not possible to determine without knowing the terms of the exit negotiated by the UK with the EU and future government decisions. There are various ways the relationship between...more

EU Council Agrees on Final Anti Tax Avoidance Directive

We wrote in February (European Commission Publishes Anti Tax Avoidance Package) about the draft EU Anti Tax Avoidance Directive (“ATAD”). On 21st June 2016, the EU Council agreed on the final text of the ATAD and it will...more

Taking a Gap Year: Delayed U.S. CbC Reporting Creates Hassle for U.S. Multinationals

Action 13 of the Organisation for Economic Co-operation and Development’s (OECD) final base erosion and profit-shifting (BEPS) report suggested the adoption of a standardized mechanism for transfer-pricing reporting. Per the...more

Private equity in Italy: market and regulatory overview

How do private equity funds typically obtain their funding? Private equity funds continued to have a diverse investor base in 2015. Although with a significant decrease from the 2014 figure of 68%, about 48% of the...more

EU: ECOFIN approves implementation of country-by-country reporting in the EU but fails to reach consensus on EU...

EU COUNTRY-BY-COUNTRY REPORTING: ADOPTED On May 25, 2016, the European Union’s Economic and Financial Affairs Council (ECOFIN) voted unanimously in favor of the implementation of proposed country-by-country reporting...more

New Public Country-by-Country Reporting of Financial Information Proposed by European Commission

Country-by-country reporting (“CBCR”) is one of the OECD BEPS deliverables (under Action 13). It is expected to be a significant tool used by tax authorities’ auditors in evaluating a multinational group’s transfer pricing...more

UK Finance Bill 2016: Royalty Withholding Tax

Domestic UK law imposes a 20% royalty withholding tax on limited types of payment and on specific categories of intellectual property. This year's Finance Bill expands the scope of intellectual property royalties that are...more

Recent Indian Tax Treaty Changes Affecting Nonresident Investments into India - Termination of Capital Gains Exemption under the...

India and Mauritius entered into a Protocol amending the double-tax treaty between India and Mauritius (the “2016 Protocol”) on May 10, 2016. Under the 2016 Protocol, following a grace period and subject to a grandfather...more

NCA and HMRC to Lead Taskforce to Investigate the Panama Papers

From early 2015, 11.5 million documents belonging to a Panamanian law firm, Mossack Fonseca, were provided to a German newspaper, Süddeutsche Zeitung, who shared them with the International Consortium of Investigative...more

Federal Budget Update

The Australian Government continued its attack on Multinational Tax Avoidance with the release of its 2016-2017 Federal Budget. Central to its Budget initiatives is the introduction of a 40% Diverted Profits Tax on large...more

WCO TCCV approves case study on TNMM transfer pricing documentation and customs valuation

During the week of 18-22 April 2016 the World Custom's Organizations Technical Committee on Customs Valuation (TCCV) held its 42nd Session in Brussels. At this session a new instrument was approved by the TCCV that contains a...more

Latin American countries focus on new legislation around tax and transfer pricing – independence limitations in Ecuador

A recent report published by the United Nations’ Economic Commission for Latin America and the Caribbean (CEPAL) calculated that Latin American countries have lost more than US$98 billion in tax revenues simply due to...more

European Commission proposes public CBC reporting: key takeaways

The European Commission has published a proposed amendment to the existing EU Accounting Directive that, if adopted, would introduce a form of public country-by-country (CbC) reporting for qualifying companies in the EU. ...more

2016 Federal Budget – Selected Tax Measures

On March 22, 2016, the Minister of Finance tabled Canada’s 2016 Federal Budget (the 2016 Budget). This was the first budget presented by the newly-elected Liberal government, which won a strong majority in the fall 2015...more

EU Anti-Tax Avoidance Directive Published: Implications For Luxembourg Corporate Taxpayers

On 28 January 2016, the European Commission published the proposal for a so-called Anti-Tax Avoidance Directive. The Directive applies to all taxpayers which are subject to corporate tax in an EU Member State, including...more

UK Budget 2016: Key Implications for Financial Services

On Wednesday March 16, 2016, George Osborne delivered his eighth budget as the U.K.’s Chancellor of the Exchequer, which included a number of announcements that will be relevant to the financial services industry....more

UK Budget 2016: Finance

From April 2017, the UK government is to cap the amount of corporation tax relief for interest to 30% of taxable earnings in the UK or the net interest to earnings ratio for the worldwide group. This is subject to a threshold...more

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