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New Transfer Pricing Regulations In Poland In Force Since January 1st, 2017
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November 16th, 2017
New transfer pricing regulations in Poland were introduced into the tax system to implement the instruments developed by OECD within BEPS framework. However, there are some different items and obligations included in Polish regulations that are not part of the OECD Guidelines.
South African Notice On Return Submission Regarding CbCR And Master File
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October 20th, 2017
South Africa issued a notice on the return to be submitted by persons in terms of the Country-by-Country Regulations. Taxpayers concerned are required to file Country-by-Country reports, master and local files.
Switzerland - Act on Country-by-Country Report Enters into Force Since 2018
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October 20th, 2017
The Federal Council decided to bring the Federal Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals (CbC Act) and the Multilateral Competent Authority Agreement of 27 January 2016 on the Exchange of Country-by-Country Reports (CbC MCAA) into force.
CbC Act and CbC MCAA .
10 Practical Tips To Manage (Tax Risk) And File Your Country-by-Country Report Before Year End!
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October 19th, 2017
No other Action of the OECD’s 15 Action Points will have wider consequences than Action 13 – “ Guidance on Transfer Pricing Documentation and Country by Country Report” – in terms of the data ammunition provided to tax authorities to perform tax risk assessment!
After issuing various guidance and handbooks since the roll out of the Final BEPS Action 13 in 2015, the OECD last week published additional guidance to BEPS Action 13: “ Handbook on effective tax risk assessment ” . This publication will assist tax authorities in carrying out tax risk assessment before embarking on a full-blown tax audit of the taxpayer.
Controversy Management After BEPS – A Unique Network Of Global Experts
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October 18th, 2017
Have tax disputes risen? “I firmly believe that there has been an increase” – Pascal Saint Amans
Post BEPS, it has become increasingly difficult to wholly identify and comply with all the legislative norms applicable to corporate taxpayers. While tax disputes have always come with extensive court battles and hefty economic burden, they now bring along an additional element of damage to a company’s and/or its major shareholders’ reputation.
RSA - From Functional Analysis to Value Chain Analysis
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October 18th, 2017
Attacks by the South African Revenue Service (“ SARS ”) on the transfer pricing practices of multinational enterprises (“ MNEs ”) are on the rise, leading to tax disputes with SARS over significant amounts of tax.
MNEs operating in South Africa provide information to SARS in various forms such as annual Corporate Income Tax returns, Country-by-Country reports as well as the extensive Transfer Pricing documentation.
Africa - Building Pleasant Investment Climate With Tax Certainty
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October 17th, 2017
The Consultative Workshop on Tax Certainty is to be held in Dar es Salaam, Tanzania on October 25, 2017. The three-day workshop will convene officials from 20 African tax authorities and ministries of finance, and experts from the OECD and the IMF.
Singapore’s Tax Incentives Meet BEPS Standards
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October 17th, 2017
The Forum on Harmful Tax Practices (FHTP) has released a progress report on preferential regimes that were reviewed in 2016 and 2017. Specifically, FHTP has assessed that Singapore’s tax incentives satisfy the international standards on countering harmful tax practices under the OECD/G20 Base Erosion and Profit Shifting (BEPS) project.
PANA Publishes Draft Report and Draft Recommendation
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October 17th, 2017
The next meeting of the Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) will take place on October 18, 2017 on which the report on its inquiry and corresponding draft recommendation will be presented.
Indentifying Maladministration .
BEPS Software Series - Automation Through Cloud Solutions
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October 17th, 2017
Are you tired out from transfer pricing (TP) compliance burden? Now it’s time to look at automated solutions. Our BEPS Software will automate data collection and the three tiered TP documentation to ensure a streamlined BEPS compliance under BEPS Action 13 requirements.
OECD - A Further Step on BEPS Action 13
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October 12th, 2017
The OECD released the Country-by-Country Reporting (CbCR) implementation status, through activations of automatic exchange relationships under the Multilateral Competent Authority Agreement on the Exchange of CbC Reports ("the CbC MCAA"). This is a further step to implement CbC Reporting in accordance with the BEPS Action 13 minimum standard.
ECOFIN - New Framework On Tax Dispute Resolution Issued
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October 12th, 2017
The EU Economic and Financial Affairs Council (ECOFIN) adopted a directive to deal with double taxation resulting from different interpretations of bilateral tax treaties or other conventions. It is the following up work of the ECOFIN meeting on May 23, 2017.
Implementation of BEPS Action 13 - Mexico and other countries of Central America
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October 12th, 2017
Whilst many countries around the world have been implementing Action 13 of BEPS, countries in Latin and Central America also continue gradually advancing in the incorporation of the Country by Country report, Master File and Local file in their domestic legislation and therefore assuming the new challenges on transfer pricing documentation recommended by the OECD.
Current Status and Implications .
Implementation Of BEPS Action 13 - Chile, Colombia, Peru and Uruguay
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October 12th, 2017
Whilst many countries around the world have been implementing Action 13 of BEPS, countries in Latin and Central America also continue gradually advancing in the incorporation of the Country by Country report, Master File and Local file in their domestic legislation and therefore assuming the new challenges on transfer pricing documentation recommended by the OECD.
Current Status and Implications .
The Netherlands Is Following The Cutting Tax Trend
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October 10th, 2017
Since October 5, 2017, the Dutch new cabinet successfully released the new tax plan in coming years. Several amendments are expected to be introduced to the present tax scheme, including changes on income tax, wealth tax and circulation tax (value added tax).
UN Releases Paper To Rise Attention To Digital Taxation
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October 10th, 2017
The United Nations published a paper on tax consequences of the digitalized economy, which gives an overview on possible issues for developing countries. It is a preparatory work for the Fifteenth Session of the Committee of Experts on International Cooperation in Tax Matters held in Geneva during October 17 to 20, 2017.
OECD - Feedback on PE Profit Allocation and Profit Splits Draft Released
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October 10th, 2017
The OECD released the public comments received on BEPS discussion drafts on attribution of profits to permanent establishments and transactional profit splits. The two discussion drafts were issued on June 22, 2017 for public feedbacks, and a public consultation will be held on November 6 to 7, 2017 in Paris.
Luxembourg Benefits Amazon With €250 million State Aid
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October 5th, 2017
The European Commission released a decision, concluding that Luxembourg has granted undue tax benefits to Amazon of around €250 million. This decision is following up the investigation launched in October 2014, when the Commission looked into a series of tax ruling practices of Member States, including the Starbucks case in the Netherlands and the Fiat case in Luxembourg.
Tallinn Summit: A Tortuous Path to Digital Taxation
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October 5th, 2017
On September 29, the leaders of the EU Member States met at the Tallinn Summit, during which the leaders gave their opinions on the digital taxation on Union level . The tax plan has received endorsement from 19 out of the 28 states, but no new agreement was reached due to the fierce division of various parties.
Ireland Failed to Recover State Aid of €13 Billion from Tech Giant
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October 5th, 2017
The European Commission announced to bring Ireland to the Court due to its negative attitude in recovering the state aid from Apple. This decision is based on Art.108(2) TFEU, Art.16(3) of Regulation 2015/1589, and the Commission's recovery notice.
TPA Global Country Summaries Update
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October 5th, 2017
Based on our day-to-day projects involving country specific requirements, TPA Global has created accurate and practical country summaries, which multinationals can utilize to make their country specific documentation packages in full compliance with local transfer pricing law and regulations.
We updated the country summaries of.
Asia - Workshop “How BEPS impacts Value Chain Analysis for Transfer Pricing purposes”
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October 5th, 2017
We would like to invite you to our Value Chain Analysis Workshop in Kuala Lumpur, Malaysia on 3 October 2017 or Jakarta, Indonesia on 5 October 2017,
“How BEPS impacts Value Chain Analysis for Transfer Pricing purposes” .
IRS Releases List Of Countries Regarding Tax Information Exchange
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October 3rd, 2017
On September 29, 2017, the Internal Revenue Service (IRS) released Revenue Procedure 2017-46, providing a list of countries regarding tax information exchange. It will form part of Internal Revenue Bulletin (IRB) 2017-41, which is supposed to be issued on October 28, 2017.
Switzerland - Act on Country-by-Country Report Adopted
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October 3rd, 2017
The Federal Council adopted the Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals. The new act will enter into force on December 1, 2017, if the referendum is not called before expiry of its deadline on October 5, 2017.
OECD: Making Dispute Resolution More Effective - MAP Peer Review Report (NEW)
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October 2nd, 2017
The following BEPS related publications have been release by the OECD.
If you are interested in the theme covered by the books mentioned above, we invite you to visit www.
UK - Belarus Income Tax Treaty Ratified
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September 29th, 2017
The UK-Belarus Income Tax Treaty was signed between the Government of the United Kingdom of Great Britain, Northern Ireland and the Government of the Republic of Belarus. The new Treaty has not entered into force yet, and the UK-Soviet income treaty signed in London in 1985 will only cease to apply between the United Kingdom and the Republic of Belarus when the new treaty comes into force.
US - Revamp Of The Advanced Pricing Agreement Template
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September 29th, 2017
The IRS released a draft of the template used for advance pricing agreement (APA) for public discussion on revision. This template is designed to systematize how taxpayers propose terms for their APAs and standardize language used in executed APAs.
US - Tax Reform Framework Released With 20% CIT
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September 28th, 2017
On September 27, 2017, the White House released a framework for the US tax reform. The framework intends to both cut the income tax burden for taxpayers and slim the extremely sophisticated tax code in the US.
EU Commission - Path Set To Fair Tax On Digital Economy
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September 28th, 2017
The European Commission launched a new EU agenda to ensure that digital economy is taxed in a fair and growth-friendly way. The Commission also adopted a Communication, in which it sets out the challenges Member States currently face when it comes to acting on this pressing issue and possible solutions.
Transfer Pricing Under BEPS In Latin American And Caribbean Countries
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September 28th, 2017
The Inter-American Center of Tax Administrations (CIAT) recently reported the outcome of seven activities since 2014 to disseminate the content of the BEPS Action Plan. The countries gave their view on the level of priority of the different actions based on their respective contexts and shared their experience in applying BEPS reports, among which Actions 8 to 10 keep receiving the highest priority level.
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Webinar - "New transfer pricing regulations in Poland in force since January 1st, 2017"
Thursday, 16 November, 2017 | 4:00 PM - 5:00 PM (CET)

Webinar - Implementation Of BEPS Action 13 - Chile, Colombia, Peru and Uruguay
Thursday, 2 November, 2017 | 4:00 PM - 5:00 PM (CET)
Wednesday, 8 November, 2017 | 4:00 PM - 5:00 PM (CET)

Webinar - Implementation of BEPS Action 13 - Mexico and other countries of Central America
Thursday, 16 November, 2017 | 4:00 PM - 5:00 PM (CET)
Wednesday, 22 November, 2017 | 4:00 PM - 5:00 PM (CET)

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