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The latest news

Value Chain Analysis Event - Functional Analysis post BEPS
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August 31st, 2017
This event is provided jointly by TPA Global and Maastricht University.
As a result of the OECD’s BEPS Action Plan, MNEs are experiencing increased exposure to tax controversies if they are not simultaneously in control of their Operating and Transfer Pricing models.
Tax Technology Event 2017 - From ‘Staying Out Of Trouble’ To ‘Being In Control’
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August 31st, 2017
This workshop is organized to assist businesses in finding their way through the world of tax technology solutions.
Thursday, 7 September 2017
South Africa - Retrospective Country-by-Country Reporting And Transfer Pricing Documentation Requirements
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August 16th, 2017
South Africans who think that their tax burden is going to decrease because country-by-country (“CbC”) reporting does not apply to their company should think again!
In addition to the recently released draft notice requiring the submission of CbC reports, master file and local file returns, the South African Revenue Service (“SARS”) has recently issued the External Business Requirements Specification (“BRS”) document, setting out CbC and Financial Data Reporting (“FDR”) requirements..
IRS Is Now Accepting Country-by-Country Reports
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August 15th, 2017
On August 11, the IRS issued a press release announcing that it is now accepting country-by-country (CbC) reports and advised that parent entities of US multinational enterprise groups should now file Form 8975 with their annual income tax return.
US Multinationals to File CbC Reports.
France and Germany Target US Home-Sharing Platform Giant
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August 15th, 2017
Airbnb faces EU clampdown for not paying 'fair share' of tax as France and Germany initiate a new European Union fight to force home-sharing platforms to pay more tax. The French finance minister Bruno Le Maire said Airbnb’s low tax bill was “unacceptable”.
ATO to Collect CbC Information from the US
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August 15th, 2017
The US and Australia have agreed to share detailed information of companies as countries signed a country-by-country report agreement. The Australian Labor party also proposed a private senators’ bill on Monday that would require private companies with more than $100m in turnover to release their annual tax information to the public.
US Tech Giants Will Face Tax Clampdown from France and Germany
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August 10th, 2017
France and Germany and other partners have paired up to secure loopholes allowing U.S. tech giants such as Alphabet Inc.’s Google, Apple Inc., Facebook Inc. and Amazon.com Inc. to reduce taxes and take hold of market share in Europe, at the cost of European companies.
Cyprus - New Transfer Pricing Rules on Intra-Group Loan
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August 10th, 2017
Cyprus Tax Department has published a new circular regarding detailed transfer pricing rules which came into force on July 1, 2017. The new rules replaced the existing rules to determine the tax base of the “back-to-back” intra-group loan on the basis of a minimum margin.
Argentina - Brazil Tax Treaty: Latest Revision
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August 10th, 2017
Argentina and Brazil signed a protocol on several significant amendments on the bilateral tax treaty between the two countries during the Mercosur Summit. The new version, however, is not in force yet, as future feedback from the public may be needed.
New Zealand - BEPS Decision on Multinationals
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August 7th, 2017
The New Zealand government confirmed final decisions regarding taxation of multinationals to address Base Erosion and Profit Shifting (BEPS) and facilitate a fairer taxation. All these changes will be implemented via a tax bill and come into force by July 2018.
Joint Action On Offshore Indirect Assets Tax
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August 3rd, 2017
The IMF, OECD, UN and World Bank Group released a draft toolkit designed to help developing countries tackle the complexities of taxing offshore indirect transfers of assets. Public feedback on practice of multinational corporations to minimize their tax liability is sought by the Platform for Collaboration on Tax.
Hong Kong - Legislation On Transfer Pricing, CbCR, Dispute Resolution
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August 3rd, 2017
On July 31, the Hong Kong’s Inland Revenue Department (IRD) has released a consultation report that follows the work of the public on the BEPS plan in 2016, which is to be implemented in Hong Kong. Comments from 26 parties can be found in the report and future policy trends are indicated.
UK Not to Become A Tax Haven
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August 2nd, 2017
In an interview with French newspaper Le Monde, Chancellor Philip Hammond has said the UK will not reduce taxes or regulations to become a tax haven in a bid to compete with European rivals after Brexit.
Background.
BRICS Agree on Memorandum of Cooperation in Tax Matters
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August 2nd, 2017
During the annual meeting of the heads of the BRICS revenue administrations held in Hangzhou on July 28, tax officials from Brazil, Russia, India, China and South Africa signed a memorandum of cooperation to enhance their mutual work on international tax matters.
Background: International Taxation.
US Border Tax Proposal Denied
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August 2nd, 2017
On July 27, a proposed controversial border-adjusted tax proposal was denied in the House of Representatives. In a released statement, the officials informed that the goal of a tax reform is to reduce tax rates “as much as possible,” but the details yet remain unclear.
TPA Global Forms Alliance With Grupo Consultor EFE™ (Mexico)
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August 1st, 2017
Grupo Consultor EFE™ is an award-winning tax consulting firm with presence in the most entrepreneurial cities in Mexico and LATAM. The firm is the leading transfer pricing advisory services provider for the mid-sized company in the LATAM region, being named Best Transfer Pricing Advisory Firm for the last consecutive years by some of the largest tax-specialized media in the world.
Value Chain Analysis After BEPS - The Roadmap To Being In Control
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August 1st, 2017
Authors: Steef Huibregtse, Raymund Gerardu and Avisha Sood - TPA Global Network, Amsterdam (the Netherlands).
As Value Chain Analysis is now a mandatory part of the annual TP documentation exercise of MNEs, it can also serve as a.
Research: The Netherlands Is The Main Channel For Corporate Tax Avoidance
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July 27th, 2017
Almost 40% of corporate investments channeled away from authorities and into tax havens travel through the UK or the Netherlands, according to a study of the ownership structures of 98m firms. The Netherlands was a conduit for 23% of corporate investments that ended in a tax haven, while the UK accounted for 14%, ahead of Switzerland (6%), Singapore (2%) and Ireland (1%).
India - ‘Capital Gains’ Taxation Affair With The Netherlands
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July 27th, 2017
Andhra Pradesh High Court has concluded that gains arising from a Dutch company’s sale of shares of an Indian immovable property company to a Singapore company do not amount to a sale of immovable property situated in India since India-Netherlands tax treaty exempts such transaction.
Background.
Saudi Arabia To Be The First GCC Country to Implement VAT In 2018
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July 25th, 2017
Saudi Arabia has issued draft implementing legislation and implementing regulations in preparation of the 1 January 2018 launch of Value Added Tax, VATlive informes. It is based on the Gulf Co-Operation Council (GCC) VAT Treaty, which provides broad guidance on the VAT regime to be introduced in 2018 in all 6 GCC states.
Ireland Launches Apple State Aid Recovery Procurement Process
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July 25th, 2017
The Irish Ministry of Finance announced the launch of the procurement process in relation to Apple state aid recovery. The Department of Finance also revealed that funds may be higher than initial €13bn estimate.
Cyprus Adjusts Tax Treatment Of Intra-Group Financing Arrangements
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July 25th, 2017
On July 21, the Cypriot Ministry of Finance informed that the Commissioner of Taxation has issued a Circular for the tax treatment of intra-group financing arrangements. This follows constructive contact with the European Commission's Directorate General for Competition.
New Memory Trainers Will Help You To Become A Knowledgeable VCA, BEPS and/or TP Business Professional
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July 23rd, 2017
e-Bright is preferred partner of TPA Global.
e-Bright will soon introducing new Memory Trainers that will help you to become a knowledgeable business professional in the following fields:.
India - A Further Step On Tax Info Exchange To Tackle Evasion
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July 21st, 2017
The Indian Finance Ministry announced that India had taken part in the global joint task force meet to discuss the information exchange issue with other countries as a follow-up work on the Panama Papers.
Collaboration with the JITSIC.
Cayman Islands - Reinforcing Financial Services
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July 21st, 2017
Cayman's Minister of Financial Services, Tara Rivers, made her first visit to London to meet UK officials and industry leaders addressing its position on Brexit, beneficial ownership, and the EUs work on blacklist of non-cooperative jurisdictions, Cayman iNews reported on July 19.
Reinforcing The Strength Of Cayman's Financial Services.
EU Consults The Public On Customs Information Exchange With 3rd Countries
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July 21st, 2017
The European Commission opened a consultation to all interested parties on exchange of customs related information with third countries. This view seeking will continue until October 16, 2017.
BEPS Action 8 on Hard-to-Value Intangibles: is this the last piece of the puzzle required by SARS to issue its updated Transfer Pricing Practice Note?
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July 19th, 2017
One of the main action items identified by South Africa’s National Treasury in its summary of the country’s position on the G20/Organisation for Economic Co-operation and Development (“OECD”) action plan on base erosion and profit shifting (“BEPS”), is the requirement for the South African Revenue Service (“SARS”) to update the Transfer Pricing Practice Note in line with the OECD Transfer Pricing Guidelines to include new guidance on the arm’s length principle and an agreed approach to ensure appropriate pricing on intangibles that are difficult to value.
Action 8 of the BEPS Action Plan mandated the development of transfer pricing rules or special measures for the transfer of Hard-To-Value Intangibles (“HTVI”) and the general rules of how to deal with HTVI can be found in section D.
Switzerland To Exchange Information with Singapore
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July 18th, 2017
Switzerland announced that it has signed an agreement on the automatic exchange of information with Singapore. On the same day, a working meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) has started in Geneva.
New Zealand Might Implement A Diverted Profits Tax
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July 18th, 2017
New Zealand's Labour party informed that, in order to fight against tax avoidance of multinational companies, it aims to introduce a diverted profits tax (DPT) which would collect an extra $600 million from multinationals over three years.
Implementing the Diverted Profits Tax.
Reminder - Mandatory CbC Reporting Notification In The Netherlands Before 1 September 2017
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July 17th, 2017
As of 1 January 2016 local Dutch entities, belonging to a multinational group that meets the threshold for Country-by-Country Reporting, must notify the Dutch tax authorities (“Belastingdienst”) of the identity and the tax residence of the Reporting Entity no later than the last day of the reporting fiscal year of such multinational group. For the first calendar year 2016 and fiscal years starting in financial year 2016 and ending later but before or on 31 August 2017, the notification deadline has been extended to 1 September 2017.
TPA Global Events 2017

We Provide Solutions - Let's Talk Business!

TAX TECHNOLOGY EVENT 2017
Amsterdam, the Netherlands
7 September 2017
 
VCA - FUNCTIONAL ANALYSIS POST BEPS
Amsterdam, the Netherlands
25-26 September 2017

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