BEPS News by region

BEPS-news-by-region

KPMG's reports of the latest tax developments from across the globe.

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BEPS

BEPSNewsFlash-Taiwan

BEPS-NewsFlash-Asia Pacific

2016/8/17 - Israel: Country-by-country reporting, transfer pricing documentation in budget plan 2016/8/8 - Asia Pacific: Country-by-country reporting, status update for region 2016/8/5 - Australia: Review of transfer pricing developments since 2012; plans for more changes 2016/8/1 -  Korea: Revised legislation, transfer pricing and country-by-country reporting 2016/7/14 - China: Transfer pricing documentation, related-party reporting guidance from BEPS project 2016/7/11 -  Hong Kong: BEPS participation, recommendations pending government action 2016/7/6 - Hong Kong: Transfer pricing and BEPS considerations—intangible property and R&D 2016/7/4 - Japan: Guidance under new transfer pricing documentation rules 2016/6/28 - New Zealand: Recommendations for foreign trusts, inbound investment, BEPS proposals 2016/6/24 - Singapore: Country-by-country reporting 2016/5/25 - Australia: Country-by-country, final Local files released 2016/5/21- China: Participation in global tax initiatives (BEPS, CRS) 2016/5/19 - Austria: Proposed legislation, transfer pricing documentation and country-by-country reporting 2016/4/27 - Japan: Country-by-country reporting requirements 2016/3/31 - Korea: Master file and local file templates are released 2016/3/19 - Turkey: Draft communiqué on transfer pricing documentation, country-by-country reporting 2016/3/17 - Indonesia: FAQs on transfer pricing 2016/3/10 - Australia: Costs of non-compliance with country-by-country reporting requirements 2016/3/2 - India: Country-by-country reporting, transfer pricing documentation rules in budget 2016 2016/2/22 - New Zealand: Implementing AEOI regime, exchange of transfer pricing rulings 2016/2/12 - Australia: Consultation on BEPS-related transfer pricing recommendations 2016/2/2 - India: Bilateral APAs with UK, concerning management charges, brand royalty 2016/1/25 - Singapore: New, updated transfer pricing guidance 2016/1/14 - Australia: Prepare now for country-by-country reporting 2016/1/5 - Korea: Master file and local file; “full” transfer pricing reporting

BEPS-NewsFlash-Europe

2016/8/30 - Ireland: EC state aid investigation, “illegal tax benefits” to multinational company of €13 billion 2016/8/22 - Liechtenstein: Automatic exchanges of CRS, country-by-country reporting 2016/8/19 - Czech Republic: Automatic exchange of APAs, country-by-country reporting proposals 2016/8/5 - Luxembourg: Automatic exchange of country-by-country reports among EU Member States 2016/8/3 -  Country-by-country reporting 2016/7/25 - Austria: New transfer pricing documentation, country-by-country rules effective for 2016 2016/7/5 - Belgium: Country-by-country reporting, transfer pricing documentation; new law is published 2016/7/1 - Germany: Country-by-country reporting, BEPS items in draft bill 2016/6/21 EU: Agreement on directive reached, new tax avoidance rules 2016/6/20 Finland: Transfer pricing documentation, country-by-country reporting draft legislation 2016/6/13 Luxembourg: Tax ruling in EC state aid investigation is published 2016/6/7 EU: Council approves country-by-country reporting, mandatory automatic exchanges of tax information 2016/5/25 Norway: Transfer pricing documentation, country-by-country reporting 2016/5/24 Netherlands: Proposed “innovation box” changes, align with BEPS recommendations 2016/5/19 Denmark: New transfer pricing documentation requirements 2016/5/16 Belgium: Draft law, country-by-country reporting and transfer pricing documentation requirements 2016/5/14 UK: Restrictions on tax deductibility of corporate interest expense, consultation 2016/5/13 Norway: Proposed legislation to implement country-by-country reporting rules 2016/5/4 Sweden: Proposed legislation, transfer pricing documentation and country-by-country reporting 2016/4/21 Switzerland: Country-by-country reporting, implementing legislation advances 2016/4/12 EU: “Public” country-by-country reporting for multinational enterprises advances 2016/4/4 UK: Discussion of BEPS-related measures in 2016 budget, Finance Bill 2016/4/1  Italy: New guidelines for international tax rulings and APAs 2016/3/28  UK: BEPS items included Finance (No. 2) Bill 2016 2016/3/24 EU: Draft proposal on “public” country-by-country reporting 2016/3/17  UK: Tax proposals in 2016 budget; timetable for BEPS implementation 2016/3/11  Luxembourg: Tax reform, addressing BEPS recommendations 2016/3/11  UK: Preparing for country-by-country reporting 2016/3/9 EU: Automatic exchange of country-by-country reporting by multinational companies 2016/3/5 Poland: Enhanced tax audit focus on transfer pricing 2016/3/4  UK: Final country-by-country reporting regulations 2016/3/4  EU: State-aid investigations of “tax rulings,” response to US concerns 2016/2/26  EC roadmap on BEPS 2016/2/26  Jersey opens consultation on Country by Country reporting 2016/2/18  EU: Double taxation, dispute resolution mechanisms consultation 2016/2/12  Belgium: New wave of transfer pricing audits 2016/1/29  EU: New anti-tax avoidance package focused on corporations 2016/1/21 France: Country-by-country reporting, transfer pricing declaration 2016/1/13  Finland: Transfer pricing documentation rules, country-by-country reporting proposal 2016/1/13  EU: Action plan for corporate tax, 2016 2016/1/11  Belgium: “Excess profit” tax advantages to be recovered from multinationals 2016/1/11  EU: Initiatives on corporate tax avoidance, scheduled for 27 January 2016/1/6  Norway: Country-by-country reporting proposal, public consultation 2016/1/6  Netherlands: New transfer pricing documentation rules enacted; country-by-country reporting

BEPS-NewsFlash-Americas

2016/8/25 - U.S. Treasury, EC’s state aid investigations of transfer pricing rulings 2016/8/9 -  Canada: Discussion, observations about country-by-country reporting proposal 2016/8/4 -  Canada: Country-by-country reporting requirements in draft legislative proposals 2016/6/30 -  Final regulations: Country-by-country reporting 2016/5/24 / US: Senators again express concerns about EC state-aid investigations 2016/4/20 Canada: Procedures for exchange of tax rulings under BEPS rules 2016/4/20  Bermuda: Country-by-country reports, automatic exchange agreement signed 2016/4/5  Canada: Country-by-country reporting in 2016 2016/4/1  US: APMA program, APA statistics for 2015 2016/3/24 Canada: Country-by-country reporting, transfer pricing proposals in 2016 federal budget 2016/3/21 IRS “practice unit” on inbound resale price method, routine distributor 2016/3/14 LB&I practice unit: Interest expense limitation, section 163(j) 2016/3/7  US: Treasury responds to Congress, EU state-aid “tax ruling” investigations 2016/3/5 LB&I practice units: Transfer pricing documentation, outbound services provided CFCs 2016/2/22 KPMG report: Initial analysis of 2016 U.S. model treaty 2016/2/17  New U.S. model income tax treaty (2016) is released 2016/2/12 US: Treasury letter to EC on state aid investigations 2016/2/5  LB&I practice units: Intercompany interest rates, cost sharing arrangements 2016/2/2 US: Bilateral APAs with India being accepted, beginning 16 February 2016/1/16Finance members urge Treasury intensify efforts, EU state aid investigations

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