In each issue that provides updates on developments in the OECD’s base erosion and profit shifting (BEPS) initiative, World Tax Advisor includes a “BEPS corner” covering these developments.
Australia: On 17 December 2015, the Australian Taxation Office (ATO) issued a “companion guideline” to the recently passed “Tax Laws Amendment (Combating Multinational Tax Avoidance) Act 2015” (for prior coverage, see World Tax Advisor, 11 December 2015). The guideline explains how the ATO will apply the new provision in the Income Tax Assessment Act 1997 concerning the implementation of country-by-country (CbC) reporting, including transfer pricing documentation. The new law will apply to all multinationals with an Australian presence (i.e. Australian resident entities or business operations conducted through an Australian permanent establishment) with annual global income of AUD 1 billion or more.
European Union: The new directive aimed at improving transparency on tax rulings is in line with the OECD’s work on the BEPS project. See the article in this issue.
France: The amended finance bill for 2015 and the finance bill for 2016 have been adopted by parliament and upheld by the constitutional court. See article in this issue.
Italy: The Stability Law for 2016 provides a number of significant changes to Italy’s tax rules, including the introduction of CbC reporting rules. See the article in this issue.
United Kingdom: Anti-hybrid legislation included in the finance bill for 2016 closely follows the OECD recommendations in this area. See UK tax alert, 11 December 2015.
United States: Proposed regulations would require annual CbC reporting by certain US taxpayers that are the ultimate parent of a multinational enterprise group. See US transfer pricing alert, dated 6 January 2016.
Back to top