The OECD proposes to reform transfer pricing documentation for multinational enterprises and to impose onerous country-by-country (CbC) reporting obligations, including disclosure of taxes paid in each country in which a...more
The overlap of Australia's new transfer pricing laws with the thin capitalization rules is causing challenges and likely duplication of analysis for taxpayers - particularly for the arm's length amount-of-debt...more
The U.S. information reporting and withholding tax regime known as "FATCA" was signed into law on March 18, 2010. In the nearly four years since, the attention of international financial institutions of every variety,...more
As part of a push for greater transparency, the Organization for Economic Cooperation and Development (OECD) released on February 13, 2014, a Common Reporting Standard (CRS) for Automatic Exchange of Financial Account...more
On February 13, 2014, the OECD published a standard for the automatic exchange of tax information among governments, intended to help fight cross-border tax evasion. Under the standard, governments would collect information...more
On February 3, 2014, the European Commission published its first Anti-Corruption Report (the “Report”). The Report covers all types of corruption, including political corruption, bribery of public officials, and private or...more
The worldwide expansion of data privacy laws and regulations has impacts that are being felt with increasing regularity in the litigation arena. Whenever data collections occur within foreign corporations or foreign...more
The Committee of Fiscal Affairs of the Organization of Economic Cooperation and Development (OECD) has released its proposed updated guidelines on transfer pricing documentation, including country-by-country reporting (CbC),...more
Six months have elapsed since the Organisation for Economic Co-operation and Development (OECD) released its 15-point action plan to address Base Erosion and Profit Shifting (BEPS). During this time, OECD has been working...more
For many years, the Organization for Economic Cooperation and Development (OECD) considered Canada a laggard when it came to anti-corruption enforcement. However, in a recent speech, Canadian Foreign Affairs Minister John...more
Germany provides insight into its tax treaty negotiation policy.
The German Federal Ministry of Finance has followed the lead of the United States, Austria and Belgium and has published a model double tax treaty for...more
As we embark on 2014, we’ve pulled together key ethics and compliance industry trends with an eye towards planning for the year ahead.
To help, we’ve asked industry experts, our colleagues at NAVEX Global and ethics...more
Happy New Year! It’s time to make your 2014 transfer pricing resolutions: read a good book, learn a new language and, of course, exercise, exercise, exercise.
2013 was a very active year from a transfer pricing...more
Brazil’s impending enforcement of its new global anti-corruption law underscores the importance of internal anti-corruption compliance programs.
Brazil’s landmark anti-corruption statute will take effect 29 January...more
In this issue:
- Enforcement Actions and Strategies
- Perennial Statutory Issues
- Unusual Developments
- Compliance Guidance
- Private Litigation
- Enforcement in the United...more
The Supreme Court of Canada recently endorsed a fundamental principle in Canadian tax law – namely that absent sham or statutory recharacterization rules, “tax law applies to transactions governed by, and the nature and legal...more
The Dutch Ministry of Finance has released a new transfer pricing Decree that is already in effect.
The New Decree, announced in late November, supersedes two earlier Decrees, that of 30 March 2001 (IFZ 2001/295) and...more
The European Union (EU) has recently turned its attention to the thriving European digital economy. In two key areas, data protection and tax, the EU seeks to increase levels of regulation and impose new...more
The Cayman Islands have moved forward in terms of peer reviews and AIFMD compliance.
OECD – Successful Compliance Ratings
The Global Forum of the Organisation for Economic Co-operation and Development met in...more
On August 1, 2013, in response to the Organization for Economic Co-operation and Development’s ("OECD") requirement that Brazil comply with the Convention on Combating Bribery of Foreign Public Officials in International...more
Former Vice Chairman of NASDAQ, David Weild IV, guest blogs about the importance of tick sizes. David is Head of Capital Markets at Grant Thornton and Founder, Chairman and CEO of Capital Markets Advisory Partners....more
I. Introduction and Executive Summary -
This paper examines the effects of a switch in the U.S. corporate tax system from the current worldwide tax system with deferral to a territorial tax system consistent with those...more
The list of Non-Cooperative States has been expanded to include Jersey, Bermuda and the British Virgin Islands. As from 1 January 2014, sums paid into these states are subject to a withholding at the source of 75% and are no...more
Earlier this month, a group of global banks known as the Thun Group released a discussion paper exploring the ways in which financial institutions might seek to integrate the U.N. Guiding Principles on Business and Human...more
At last month’s summit in St. Petersburg, Russia, G20 leaders backed two ambitious proposals issued by the Organization for Economic Co-operation and Development (OECD), including the establishment of a global model for the...more
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