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European Council Revises its EU List of non-cooperative Jurisdictions
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February 20th, 2020
The European Council stated that a number of jurisdictions have not taken sufficient steps to implement their commitments by the agreed deadline, nor engaged in a meaningful dialogue that could lead to such commitments. Subsequently, the Council revised the EU list of non-cooperative jurisdictions for tax purposes.
China Implements Tax Relief Policies to Address Coronavirus Outbreak
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February 19th, 2020
The Chinese Ministry of Finance and the State Administration of Taxation published several bulletins on tax relief policies to limit the economic impact of the coronavirus epidemic on businesses and individuals. These tax relief policies will be implemented from January 1, 2020.
Latvia Publishes Law Implementing Hybrid Mismatch Measures and Other Amendments
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February 14th, 2020
Latvia published the law with amendments to the Corporate Income Tax Act in its official gazette. The law entered into force on February 12, 2020.
Switzerland Updates Safe Harbour Interest Rates for Intercompany Loans
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February 13th, 2020
The Swiss Federal Tax Administration (SFTA) published two circulars on updated safe harbour interest rates for intercompany loans for 2020.
Loans to related parties in Swiss francs .
OECD Releases Consultation Document on the Review of Country-by-Country Reporting
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February 10th, 2020
As part of the ongoing work of the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework), the OECD released a consultation document on the review of Country-by-Country Reporting (CbCR). The OECD invites public comments on the Review of the BEPS Action 13 minimum standard.
OECD Publishes Statement on the Tax Challenges Arising from the Digitalisation of the Economy
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February 5th, 2020
The OECD/G20 Inclusive Framework on BEPS published a statement on the two-pillar approach to address the tax challenges arising from the digitalisation of the economy. In their meeting of January 29-30, the members of the Inclusive Framework (IF) affirmed their commitment to reach an agreement on a consensus-based solution by the end of 2020.
Germany Publishes Consultation Agreement on MAP with the Netherlands on DTA
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January 31st, 2020
The German Ministry of Finance published a consultation agreement between the competent authorities of Germany and the Netherlands. The agreement concerns the implementation of the Mutual Agreement Procedure (MAP) under the Double Taxation Agreement (DTA) of 2012, as amended by the protocol of 2016.
Estonia Publishes Regulations for Implementation of DAC6 Requirements
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January 28th, 2020
Estonia published 2 regulations for the implementation of the DAC6 requirements on reportable cross-border tax planning arrangements in the official gazette.
These regulations are based on the amendments to the Tax Information Exchange Act, accepted by law on December 18, 2019.
Australia Reviews International Arrangements that Mischaracterise Australian Activities Connected with the DEMPE of Intangibles
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January 23rd, 2020
The Australian Taxation Office (ATO) announced that it is reviewing international arrangements that mischaracterise Australian activities connected with the development, enhancement, maintenance, protection and exploitation (DEMPE) of intangible assets. Concerns are that these arrangements may be non-arm's length or structured to avoid tax obligations, resulting in inappropriate outcomes for Australian tax purposes.
OECD Tax Officials Discuss Pillar 1 and 2
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January 21st, 2020
The Federation of German Industries (FDI) hosts its annual tax conference, addressing the tax challenges or the digitization of the economy. In this conference, among others OECD tax officials discussed the status of Pillar 1 and 2.
US: Maryland Proposes Digital Advertising Tax
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January 16th, 2020
In the Senate of Maryland, a bill has been introduced that proposes the taxation of digital advertising. If the bill passes, it would be the first digital services tax on gross revenue introduced by any State in the US.
Colombia Sets Transfer Pricing Documentation Requirements for 2020
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January 14th, 2020
The government of Colombia published decree 2345 concerning tax regulations for natural and legal persons for the year 2020. The decree sets out the deadlines for the tax return filing and payment, as well as the deadlines for filing TP documentation.
Dutch Senate adopts Tax Plan 2020
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December 19th, 2019
The Dutch senate approved more than 50 tax measures for individuals and businesses. The measures are part of the Tax Plan 2020.
TPA Global's Matrix on Key Transfer Pricing Issues regarding Treasury Activities
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December 18th, 2019
The UN released an updated draft on financial transactions in April 2019, which in addition to the discussion draft released by OECD in 2018, provides guidance on the disputes in transfer pricing issues. Here we compare the two drafts and advanced domestic practices (i.
ECOFIN Endorses EU Code of Conduct Group Report
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December 17th, 2019
During the Economic and Financial Affairs Council (ECOFIN) meeting a report from the Code of Conduct Group (COCG) was endorsed. Earlier, the Council of the EU published the report that involves the work of the COCG in the second half of 2019.
Turkey Enacts New Law on Digital Services Tax
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December 13th, 2019
Turkey published Law No. 7194 in its Official Gazette. By means of this law, Digital Services Tax, Tax on high-valuable property, and Accommodation Tax have been established. In addition, some amendments and additions have been made in certain articles of Real Estate Tax Law No 1319, Expense Tax Law No 6802, Income Tax Law No 193 and Tax Procedure Law No 213.
Bulgaria Amends Corporate Income Tax Act
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December 10th, 2019
Bulgaria published the law on amendments to its Corporate Income Tax Act in its official state gazette. The amendments were adopted by the 44th National Assembly on November 21, 2019.
EU Ministers Fail to Agree on Public CbCR
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December 6th, 2019
The EU Competitiveness Council (COMPET) failed to agree on a directive concerning disclosure of income tax information by large international companies. EU Ministers responsible for industry and the internal market met in Brussels to discuss, among others, Country-by-Country reporting (CbCR).
US: Final and Proposed Regulations Regarding Foreign Tax Credits and Base Erosion and Anti-abuse Tax
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December 3rd, 2019
US Treasury and IRS have issued proposed and final regulations relating to Foreign Tax Credits (FTC) and the Base Erosion and Anti-abuse Tax (BEAT). These are significant international tax provisions of the Tax Cuts and Jobs Act (TCJA).
Germany and US: Joint Statement on Spontaneous Exchange of CbC Reports
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November 28th, 2019
In light of the demand for increased international tax transparency, the Competent Authorities of the US and Germany have made a joint statement, concerning the exchange of CbC Reports with respect to fiscal years of MNE Groups commencing on or after January 1, 2018 and before January 1,2019.
The governments of the countries are negotiating on an intergovernmental agreement and a competent authority arrangement to allow for the automatic exchange of CbC Reports.
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