Category: Controlled Foreign Companies

Business / Canada / Compliant / Controlled Foreign Companies / Corporate Tax / Insurance / Related party Transactions / Tax Authority / Transfer pricing

Canada: The Importance Of Tax Due Diligence When Buying A Business

Published by: Mondaq - July 8, 2022

Buying a business is rarely a straightforward decision. In order to get the most out of a potential deal, buyers need to be aware of key risks and pitfalls so they can incorporate mitigation strategies into their deal negotiations. The challenge for buyers is ensuring that no significant risks are missed when making their assessment. This can be difficult, particularly when buyers focus primarily on quality of earnings analyses or other non-financial and tax diligence reviews. ... - Continue reading

Controlled Foreign Companies / OECD / Offshore Accounts / Offshore Tax Evasion / Pakistan / Tax Amnesty / Tax Avoidance / Tax Transparency

Pakistan to start receiving information on offshore accounts in September

Posted On: June 22, 2018

ISLAMABAD: Pakistan is poised to receive information about offshore financial accounts in September 2018. This was stated by the spokesperson and member policy Dr Muhammad Iqbal while addressing a press conference on the ongoing Tax Amnesty Scheme on Friday. Due to the initiatives by the Organisation for Economic Co-operation and… – Continue reading

Base Erosion & Profit Shifting / China / Controlled Foreign Companies / Jurisdiction / Mutual Agreement Procedure / Tax Authority / Tax Avoidance / Tax Reform / Transfer pricing

Transfer Pricing Investigation in China: Understanding the Latest Adjustments

Posted On: May 2, 2017

New transfer pricing regulations issued by the State Administration of Taxation (SAT), the Measures for Administration of Special Tax Investigation Adjustment and Mutual Agreement Procedures (“the Measures”), came into effect on May 1, 2017. The Measures consolidate China’s pre-existing regulations regarding self-adjustment and outbound payments with the new transfer pricing… – Continue reading

Controlled Foreign Companies / Internal Revenue Service (IRS) / Legislation / Offshore Companies / Offshore Tax Evasion / Property / Related party Transactions / Tax Laws / USA

Combatting Foreign Tax Evasion With New Filing Requirements for Foreign-Owned Disregarded Entities: Tax Update, Volume 2017, Issue 2

Posted On: March 13, 2017

The new regulations expand the filing requirements for Form 5472 to include disregarded entities with foreign owners when there are certain reportable transactions. If a non-U.S. person (individual or corporation) owns 100 percent of the stock of a U.S. corporate subsidiary, the subsidiary needs to obtain an employer identification number… – Continue reading

Anti-Tax Avoidance Package / Blacklist update / Controlled Foreign Companies / EU / Legislation / Regulatory / Tax Haven / Withholding Tax

EU Mulls Tax Sanctions for Countries Branded Tax Havens

Posted On: March 2, 2017

Countries that end up on the European Union’s list of tax havens could subject companies operating within their borders to tax sanctions—such as withholding taxes and denied deductions for royalty payments—damaging the businesses’ ability to offset losses in the jurisdictions. Following a March 1 meeting, politicians identified a range of… – Continue reading

Common Consolidated Corporate Tax Base / Controlled Foreign Companies / Corporate Tax / Dividends / Double Taxation Agreement / ECOFIN / EU / G20 / Interest / Luxembourg / Multinationals / Netherlands / OECD / Offshore / State Aid / Tax Planning / Tax Reform / Tax treaties / Transfer pricing

Netherlands: Trends I Netherlands Moves Away From Fiscal Offshore Industry

Posted On: February 27, 2017

The Netherlands is slowly but surely steering away from facilitating the use of its corporate income tax system by companies that are set up merely to obtain tax benefits. These companies, which often do not actually carry out activities in the Netherlands, have contributed to the perception among policy makers… – Continue reading

Anti money laundering / Australia / Controlled Foreign Companies / Directors / Financial markets / Legislation / New Zealand / Offshore Companies / Regulatory

Govt seeks to lift focus on nominee directors & bring anti-money laundering into the picture in attempt to clean up Financial Service Providers Register

Posted On: February 21, 2017

The Government is considering making companies include detail of who their supervisor is under the Anti-Money Laundering and Countering Financing of Terrorism Act (AML/CFT Act) as it strives to clean up the Financial Service Providers Register (FSPR). This suggestion is included in a consultation paper on a Financial Services Legislation… – Continue reading

Base Erosion & Profit Shifting / Beneficial Ownership / Blacklist update / Business / Cayman Islands / Common Reporting Standard / Controlled Foreign Companies / Corporate Tax / EU / Europe / Income Tax / Italy / Jurisdiction / OECD / Offshore / Shell / Tax Evasion / Tax Haven / Tax Information Exchange Agreements / Tax Transparency

Cayman may find itself on EU’s ‘non-cooperative jurisdictions’ list

Posted On: November 15, 2016

Cayman could find itself on a new EU list of “non-cooperative jurisdictions” in tax matters after the European Council of finance ministers published the criteria for including third countries in the blacklist last week. The provisions emphasize that a jurisdiction “should not facilitate offshore structures or arrangements aimed at attracting… – Continue reading

Capital gains / Controlled Foreign Companies / Corporate Tax / Directors / Dividends / Double Tax Treaty / EU / Incorporation / Legislation / Limited Liability Company / Residence / Statutory / Tax Credit / Withholding Tax

Ireland: Holding Companies In Ireland – August 2016

Posted On: August 24, 2016

Ireland has become a destination of choice for holding companies due to its capital gains participation exemption, generous foreign tax credit system, membership of the EU, ever expanding double tax treaty (“DTT“) network (72 signed, with 70 in effect), lack of controlled foreign companies legislation, thin capitalisation rules and the… – Continue reading

Common Consolidated Corporate Tax Base / Controlled Foreign Companies / Corporate Tax / Dividends / Double Tax Treaty / EU / Europe / Exemptions / George Osborne / Income Tax / Individuals / Inheritance Tax / Inversion / Investments / Jurisdiction / OECD / Parent-Subsidiary Directive / Permanent establishment / Real Estate / Revenue / Shares / Stamp Duty / State Aid / Tax Avoidance / Tax Exempt / Tax Laws / Tax treaties / Transfer pricing / United Kingdom / VAT / Withholding Tax

Brexit – The UK and International Tax Consequences

Posted On: July 2, 2016

The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications of Brexit, this OnPoint also considers some of the potential tax implications from the perspective of… – Continue reading

Asia / Australia / Base Erosion & Profit Shifting / Beijing / Business / China / Controlled Foreign Companies / Corporate Tax / Directors / EU / Europe / Framework / G20 / India / Interest / Japan / KPMG / Legislation / Malaysia / Multinationals / OECD / Panama / Singapore / Tax Avoidance / Tax competition / Tax Laws / Tax Planning / Thailand / Transfer pricing / United Kingdom / Vietnam

How new EU tax laws impact Thai firms

Posted On: June 30, 2016

THAI MULTINATIONAL companies will be impacted on their cross-border business activities due to rapidly evolving tax laws in Europe and Asia-Pacific. For instance, the European Union (EU) achieved a groundbreaking result on June 20 by agreeing to a package of tax measures to combat corporate tax avoidance, which will be… – Continue reading

Controlled Foreign Companies / Inequality / Offshore / Personal Income Tax / Profit Shifting / South Africa / Tax Amnesty / Tax evasion investigations / Tax Laws / Tax Planning

BUDGET2016 – IS THERE ROOM TO PAY MORE TAXES?

Posted On: February 23, 2016

Anthea Scholtz calls for a careful balance between ‘spending’ and ‘revenue-generating’ activities. All eyes will be on Parliament on 24 February 2016 when South Africa’s annual national Budget will be presented by the newly re-appointed Minister of Finance Pravin Gordhan. The Budget speech has over the years given South Africans… – Continue reading

Banking / Base Erosion & Profit Shifting / Belgium / Controlled Foreign Companies / Corporates / Dividends / EU / Europe / Jurisdiction / Malta / Multinationals / Starbucks / Tax competition / VAT

Ding ding, seconds out on Malta’s fight to stop Brussels’s tax plans

Posted On: February 23, 2016

Malta has always insisted it is no tax haven, but it employs a system which allows foreign shareholders to claim a six-sevenths’ refund on their taxed dividends, taxed at the maximum 35%. There’s a new battle lining up for the Maltese government inside Brussels: an aggressive fight against tax avoidance… – Continue reading

Beneficial Ownership / Capital gains / Controlled Foreign Companies / Corporates / Dividends / Double Taxation / EU / Individuals / Jurisdiction / Loans / Offshore / Offshore Companies / Residency / Russia / Statutory / Tax Laws

A New Set of Amendments to the Russian CFC and Beneficial Ownership Rules

Posted On: February 18, 2016

On February 15, 2016, the President of the Russian Federation signed Federal Law No. 32-FZ “On Amendments to the First and Second Parts of the Russian Tax Code (with Respect to the Taxation of Controlled Foreign Companies and the Income of Foreign Organizations)”, introducing a new set of amendments to… – Continue reading

Base Erosion & Profit Shifting / Belgium / Controlled Foreign Companies / EU / Google / Ikea / Ingvar Kamprad / Ireland / Jurisdiction / Liechtenstein / Netherlands / OECD / Pierre Moscovici / Royalties / Sweden / Tax Laws / Withholding Tax

Ikea avoiding tax liability, report claims

Posted On: February 13, 2016

EU countries may have lost out on more than €1 billion in tax revenues between 2009 and 2014 due to aggressive tax strategies by furniture giantIkea, a new report has claimed. The report, commissioned by the Green/EFA group in the European Parliament into the tax affairs of the private company,… – Continue reading

Anti-Tax Avoidance Package / Base Erosion & Profit Shifting / Controlled Foreign Companies / EU / Europe / European Commission / European Parliament / Individuals / OECD / Offshore / Offshore Insurance / Profit Shifting / Tax Credit / Tax treaties

EU targets reinsurance arrangements

Posted On: January 29, 2016

The EU’s anti-base erosion and profit shifting (BEPS) proposals could have consequences for captives in Europe, as politicians pinpoint reinsurance arrangements as a means of unfair tax avoidance. The European Commission introduced a range of anti-tax avoidance proposals on 28 January, following the release of the Organisation for Economic Co-operation… – Continue reading

Base Erosion & Profit Shifting / Budget / Business / Controlled Foreign Companies / Country-by-Country (CbyC) Reporting / Europe / India / Interest / Investments / Jurisdiction / Multinationals / Profit Shifting / Transfer pricing / USA

BEPS rules to be made compulsory from 1 April

Posted On: January 22, 2016

India to change laws in Union Budget to make country-by-country reporting mandatory for Indian multinationals New Delhi: India will change laws in the upcoming budget to make country-by-country reporting mandatory for Indian multinationals to ensure they follow so-called base erosion and profit shifting (BEPS) guidelines. The norms were announced in… – Continue reading

Chile / Controlled Foreign Companies / Double Tax Treaty / Jurisdiction / Redomiciliation / Residence / Residency / Tax Reform

Redomiciliation of foreign companies

Posted On: January 22, 2016

The redomiciliation of companies (ie, movement of a company incorporated in one jurisdiction to another, retaining its legal character) is not recognised under Chilean law. This means that in order to move to Chile, a foreign company must establish a branch or create a subsidiary there. It cannot move its… – Continue reading

Capital gains / Controlled Foreign Companies / Double Taxation / Investments / Jurisdiction / Mauritius / Shares / South Africa / Tax Laws

Uncompetitive tax?

Posted On: January 22, 2016

Generally, if a South African taxpayer sells shares in a foreign company, he will be hit with South African capital gains tax (CGT) on any gain realised on that sale. However, South Africa provides exemptions from this CGT in certain circumstances, one of which relates to the sale of foreign… – Continue reading

Activity / Business / Controlled Foreign Companies / Deloitte / India / Investments / Jurisdiction / KPMG / Multinationals / Place of Effective Management (PoEM) / Residence / Residency / South Africa

Implementation of POEM rules may hit investments

Posted On: January 20, 2016

The implementation of place of effective management (POEM) rules in the current scenario in India could not only hurt the nation’s outbound investments, but also discourage overseas multinational companies from setting up their regional hubs here, feel industry watchers. The draft guidelines for implementing POEM, which was released on December… – Continue reading

Controlled Foreign Companies / Dividends / Double Taxation / Gaar / Incorporation / India / Investments / Legislation / OECD / Place of Effective Management (PoEM) / Residence / Royalties / Shell / Tax Laws / Tax treaties / Transfer pricing

PoEM not the only solution

Posted On: January 18, 2016

The change in definition of an Indian resident company under the Income-Tax Act—from one whose affairs are wholly controlled and managed in India to one whose Place of Effective Management (PoEM) is in India—and the subsequent draft guidelines are giving anxious moments to votaries of simplifying the investment climate in… – Continue reading

Channel Islands / Controlled Foreign Companies / Europe / Guernsey / Italy / Jersey

Italy’s ‘white listing’ of Channel Islands important step in attracting European business, says Ogier partner

Posted On: January 12, 2016

Ogier partner Marcus Leese has welcomed news from Italy that Guernsey and Jersey are no longer on any Italian ‘black lists’ and will be included on Italy’s ‘white lists’ from early 2016, reports Isle News. Among other benefits, it is anticipated that this will enable Italian resident investors to invest… – Continue reading

Base Erosion & Profit Shifting / Canada / Controlled Foreign Companies / Denmark / India / Legislation / OECD / Tax treaties / Transfer pricing / United Kingdom / USA

Transfer pricing rules with wider ambit soon

Posted On: January 11, 2016

Changes in I-T Act likely to curb tax evasion by multinational companies The government might change transfer pricing provisions in Budget 2016-17 to ensure companies with overseas presence and consolidated revenue of more than Rs 5,000 crore comply with extensive data reporting and documentation. Legislative changes in the Income Tax… – Continue reading

Base Erosion & Profit Shifting / Beneficial Ownership / Brazil / Canada / Capital gains / Controlled Foreign Companies / Denmark / Dividends / Double Taxation / Ecuador / G20 / OECD / Residency / Royalties / Shares / Spain / Tax Credit / Tax treaties / Turkey

Brazil: Tax Treaty Series: The Bilateral Income Tax Treaty Between Brazil And Canada

Posted On: January 11, 2016

This is the first of our series of posts on Brazilian tax treaties. In each post we will provide an overview of a specific tax treaty between Brazil and a particular foreign country, as well as comments on any Brazilian administrative or judicial precedents applying the treaty, and highlights on… – Continue reading

Controlled Foreign Companies / Thailand

Thailand cracking down on foreign-controlled firms using locals as nominees

Posted On: January 10, 2016

THE COMMERCE Ministry’s Business Development Department will this year expand its investigation into the use of Thai nationals as nominees for foreign-controlled companies in nine provinces where it suspects the illegal practice is widespread. This year, three additional provinces will be monitored – Krabi, Trat (Koh Chang), and Chiang Rai…. – Continue reading

Australia / Automatic Exchange of Information / Base Erosion & Profit Shifting / Controlled Foreign Companies / ECOFIN / G20 / Gaar / Germany / Hybrids / Intellectual Property / Japan / Legislation / Liechtenstein / Luxembourg / Netherlands / OECD / Permanent establishment / Switzerland / Tax Planning / Tax treaties / Transfer pricing / United Kingdom / USA

Luxembourg Tax Alert 2016-02

Posted On: January 8, 2016

January 2016 You will find below a summary of some of the most important tax developments that have happened since the release of our last newsletter, at OECD, EU or country level, in the area of tax transparency and the fight against tax avoidance. EU – Tax transparency and anti-BEPS… – Continue reading

Controlled Foreign Companies / Offshore Investments / Real Estate / Tax Credit / USA

PATH Act Enacts Notable Changes to REIT and FIRPTA Provisions

Posted On: January 5, 2016

On Friday, December 18, 2015, President Barack Obama signed the “Protecting Americans from Tax Hikes Act of 2015” (“PATH Act”). Our December 10, 2015 client alert discussed significant proposed changes to the rules governing real estate investment trusts (“REITs”) and the Foreign Investment in Real Property Tax Act of 1980… – Continue reading

Controlled Foreign Companies / Dividends / USA

Dividends from Foreign Corporations Part III: “Controlled Foreign Corporations”

Posted On: January 4, 2016

As will be recalled from the previous blog posting that discussed so-called “Controlled Foreign Corporations” (CFC), a United States shareholder of a CFC can possibly be treated as having received “dividend” income at various times. These are when the US shareholder (i) has current income inclusions from the CFC under… – Continue reading

Beneficial Ownership / Controlled Foreign Companies / FATCA / Legislation / Residency / Russia / Tax Amnesty

Russia: End of 2015 Changes on Taxes and Reporting on Bank Accounts

Posted On: January 4, 2016

New actions for advisors to consider in light of these developments In the last quarter of 2015, Russia saw a flurry of changes concerning the tax amnesty program, de-offshoring and the reporting of foreign accounts. We highlight the most significant developments below. What the New Rules Say Tax amnesty. On… – Continue reading

Australia / Capital gains / Chevron / China / Controlled Foreign Companies / Forms / Legislation / Permanent establishment / Transfer pricing

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Posted On: December 18, 2015

Case law Chevron appeal to the Full Federal Court Chevron Australia Holdings Pty Ltd has appealed the decision of the Federal Court in Chevron Australia Holdings Pty Ltd v Commissioner of Taxation (No 4) [2015] FCA 1092 to the Full Federal Court. For details of the Federal Court decision, please… – Continue reading

Australia / Controlled Foreign Companies / Gaar / Offshore Companies / Transfer pricing

The Australian Taxation Office releases a TaxPayer Alert on arrangements involving offshore procurement hubs

Posted On: December 15, 2015

The Australian Taxation Office (ATO) has released a Taxpayer alert on arrangements involving the use of offshore entities which source goods (procurement hub) on behalf of Australian resident multi-national enterprises (MNEs) (TA 2015/5). In the alert the ATO announces that it is currently reviewing arrangements involving the use of offshore… – Continue reading

Controlled Foreign Companies / Dividends / General Electric / Royalties / Tax Credit / USA

Permanently support families, not corporate tax giveaways

Posted On: December 11, 2015

Temporary lapses of judgment can be corrected. Permanent mistakes are harder to fix. Congress is poised to offer very costly permanent tax giveaways to powerful corporations. It is also considering renewing more modest tax credits that encourage work and support millions of low-wage workers and their children. This is an… – Continue reading

Base Erosion & Profit Shifting / Capital gains / Controlled Foreign Companies / Corporates / Dividends / Gaar / Legislation / Offshore Trusts / Permanent establishment / Residence / Shares / South Africa / Tax Credit / Transfer pricing

Tax Amendments 2015

Posted On: December 10, 2015

INTRODUCTION The Taxation Laws Amendment Act, 2015 and the Tax Administration Laws Amendment Act, 2015 have now both been passed by Parliament, but await signature by the President. Once again, and for the second year running, the number and scope of the changes to the various fiscal Acts (mainly the… – Continue reading

Base Erosion & Profit Shifting / Controlled Foreign Companies / Cyprus / Facebook / G20 / India / Investments / Legislation / Mauritius / OECD / Permanent establishment / Tax treaties / Transfer pricing / USA

‘India examining how to tax in a digital eco’

Posted On: December 9, 2015

Akhilesh Ranjan, joint secretary (foreign tax), who led India’s initiative in the BEPS project, candidly shared his views on India’s plans for its implementation and what lies in the future. The fundamental principle of the BEPS project, is that income of MNCs should be taxed in that country where economic… – Continue reading

Base Erosion & Profit Shifting / Controlled Foreign Companies / ECOFIN / EU / Gaar / Hybrids / Legislation / OECD / Parent-Subsidiary Directive / Permanent establishment / Royalties / Tax Planning / Tax treaties / Transfer pricing

EU Ministers Agree Initial EU BEPS Response

Posted On: December 9, 2015

The European Union’s Economic and Financial Affairs Council agreed a work plan in response to the OECD’s base erosion and profit shifting recommendations at its meeting on December 8. Following the meeting, ECOFIN – comprised of finance and economy ministers from all member states – released a list of agreed… – Continue reading

Africa / Base Erosion & Profit Shifting / Capital gains / Controlled Foreign Companies / Dividends / DTA / Fees / Gaar / Lease / Legislation / Offshore Trusts / Permanent establishment / Residence / Shares / South Africa / Tax Credit / Tax Laws / Tax treaties / Transfer pricing / Withholding tax rules

Tax amendments – 2015

Posted On: December 8, 2015

INTRODUCTION The Taxation Laws Amendment Act, 2015 and the Tax Administration Laws Amendment Act, 2015 have both now been passed by Parliament, but await signature by the President. Once again, and now for the second year running, the number and scope of the changes to the various fiscal Acts (mainly… – Continue reading

Base Erosion & Profit Shifting / Controlled Foreign Companies / Double Taxation / Legislation / Mexico / OECD / Permanent establishment / Tax Planning / Tax treaties / Transfer pricing / Treaty Abuse

The ABC of BEPS project to avoid double taxation

Posted On: December 7, 2015

The plan seeks to limit the fiscal erosion through interest deduction explains Alma Gutierrez; also seeks to prevent abuses in treaties and strengthening of controlled foreign companies rules. MEXICO CITY (CNNExpansión) – The Organisation for Economic Co-operation and Development (OECD) is a forum where the governments of different countries, including… – Continue reading

Australia / Base Erosion & Profit Shifting / Canada / China / Controlled Foreign Companies / Double Taxation / Earnings stripping / EU / Europe / G20 / Germany / Investments / Legislation / OECD / Offshore Companies / Permanent establishment / Profit Shifting / South Korea / Spain / State Aid / Tax Planning / Tax treaties / Transfer pricing / United Kingdom

What CFOs Need to Know About BEPS

Posted On: December 7, 2015

The Base Erosion and Profit Shifting (BEPS) project is an initiative being pursued by the Organization of Economic Cooperation and Development (OECD) to curtail perceived exploitation of international tax rules and loopholes by multinational enterprises (MNEs). The OECD’s BEPS project was initiated in 2013 at the request of the Group… – Continue reading

Apple / Controlled Foreign Companies / General Electric / Google / Investments / New Jersey / Profit Shifting / USA

A battle over billions in business tax incentives

Posted On: December 4, 2015

Deep in the $1.1 trillion dollar spending bill that Congress has to pass by Dec. 11 to avoid a government shutdown are 50 annual “tax extenders” that would provide tens of billions of dollars in tax relief for the private sector. Advocates say these measures, which have been around for… – Continue reading

Controlled Foreign Companies / Dividends / Hong Kong / Italy / KPMG / Residence

Italy: Decree removes Hong Kong from certain “black lists”

Posted On: December 4, 2015

Italy has removed Hong Kong from two of three “black lists.” A ministerial decree in November 2015 removed Hong Kong from the black lists that apply with respect to: The Italian controlled foreign corporation (CFC) rules and the full taxation of inbound dividends Costs that arise in transactions between Italian… – Continue reading

Advance Pricing Agreement / Base Erosion & Profit Shifting / China / Controlled Foreign Companies / Double Taxation / Fees / G20 / Gaar / Investments / OECD / Profit Shifting / Royalties / Transfer pricing

China’s new transfer pricing guidelines and BEPS

Posted On: December 4, 2015

The highly significant changes to transfer pricing guidance planned for under the SAT’s public discussion draft on ‘Special Tax Adjustments’ (yet to be finalised at the time of writing), and the impact of these changes in the light of evolving Chinese transfer pricing enforcement practice is the focus of this… – Continue reading

Africa / Base Erosion & Profit Shifting / Botswana / Burkina Faso / Controlled Foreign Companies / G20 / Ghana / Kenya / Legislation / Nigeria / Offshore Companies / Permanent establishment / Profit Shifting / Senegal / Somalia / South Africa / South Sudan / Sudan / Tanzania / Tax Laws / Tax treaties / Transfer pricing / Uganda

EAC STATES ADOPT NEW MEASURES TO CURB TAX LOSS

Posted On: November 30, 2015

Multinationals operating in Kenya, Tanzania and Uganda will be among the first in Africa to feel the impact of new measures to be adopted in January to curb tax losses caused by manipulation of contracts between related companies. The three countries together with Nigeria, Ghana, Burkina Faso, Senegal, Botswana and… – Continue reading

Controlled Foreign Companies / Earnings stripping / Inversion / Residence / USA

United States: Treasury And IRS Issue Additional Anti-Inversion Notice

Posted On: November 27, 2015

The Treasury Department and the IRS released Notice 2015-79 (the “2015 Notice”) on November 19th to further limit expatriation transactions and to supplement the anti-inversion guidance issued by them on September 22, 2014 (the “2014 Notice”). The 2015 Notice states that Treasury and the IRS will issue Treasury regulations to… – Continue reading

Automatic Exchange of Information / Base Erosion & Profit Shifting / Controlled Foreign Companies / Double Taxation / DTA / G20 / Intellectual Property / Investments / Legislation / OECD / Peru / Profit Shifting / Tax treaties / Transfer pricing

Worldwide: Final BEPS Reports Issued By OECD

Posted On: November 26, 2015

The OECD published 13 final reports along with an explanatory statement under its base erosion and profit shifting (BEPS) project on the 5th October 2015. This was endorsed three days later on the 8th October 2015 by the G20 Finance Ministers’ meeting in Peru’. The BEPS project outlines 15 action… – Continue reading

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