OECD: Guidance on the Implementation of Country-by-Country Reporting

The OECD has just released its “Guidance on the Implementation of Country-by-Country Reporting”. CbC reporting is one of the cornerstone of the BEPS initiative. The Communiqué explains that: “A key pillar of the project focused on ensuring transparency while promoting increased certainty and predictability. One of the main outcomes of that work has been the […]

Posted by Robert Robillard
On 29 June 2016
0 Comments
Base Erosion and Profit Shifting (BEPS), BEPS, BEPS Action 13, Country-by-country (CbC) reporting template, Guidance on the Implementation of Country-by-Country Reporting

What the BEPS? Brexit!

Obviously Brexit is rattling the EU today (and the world). Financial markets are (likely temporarily) in a free fall. This shall pass… The British pound is getting hammered. This too shall pass… On the tax front, Common Consolidated Corporate Tax Base (CCCTB) just got slapped across the face. Fairly hard at that. The Anti Tax Avoidance Package […]

Posted by Robert Robillard
On 24 June 2016
0 Comments
Anti Tax Avoidance Package, Base Erosion and Profit Shifting (BEPS), BEPS, Brexit, CCCTB, Common Consolidated Corporate Tax Base (CCCTB)

BEPS: “Assume a Can Opener”…

“Assume a can opener”, says the economist stuck on a desert island with his tuna can (The Money Game, Adam Smith)… BEPS and CCCTB fans alike are nowadays rejoicing: “assume fair taxation”… In the latest version of the Anti Tax Avoidance Package Q&A, the European Commission explains with absolute certainty: “Corporate tax avoidance deprives public budgets of billions of euros […]

Posted by Robert Robillard
On 22 June 2016
0 Comments
Anti-Tax Avoidance Package EU, Base Erosion and Profit Shifting (BEPS), BEPS, CCCTB, Common Consolidated Corporate Tax Base (CCCTB)

BEPS Rules Now Officially Part of the OECD Transfer Pricing Guidelines

The OECD recently indicated: “On 23 May 2016, the OECD Council approved the amendments to the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“Transfer Pricing Guidelines”), as set out in the 2015 BEPS Report on Actions 8-10 “Aligning Transfer Pricing Outcomes with Value Creation” and the 2015 BEPS Report on Action 13 “Transfer […]

Posted by Robert Robillard
On 20 June 2016
0 Comments
Base Erosion and Profit Shifting (BEPS), BEPS, Collaboration on Tax

ICC: What the BEPS?

The International Chamber of Commerce recently indicated: “[ICC] recognizes the efforts of an increasing number of tax authorities to revise their tax policies in response to the international guidelines outlined in the G20 mandated Organisation for Economic Co-operation and Development (OECD) Base Erosion Profit Shifting (BEPS) project. ICC urges national governments to seriously consider the […]

Posted by Robert Robillard
On 6 June 2016
0 Comments
Base Erosion and Profit Shifting (BEPS), BEPS

OECD: Multilateral Instrument to Implement Tax-Treaty BEPS Measures

The OECD has just released a new discussion draft pertaining to the multilateral instrument to implement the tax-treaty related BEPS measures. The OECD explains: “The Request for Input outlines the background and purpose of the multilateral instrument and describes briefly the technical issues arising from its development, including the issues to be considered in the […]

Posted by Robert Robillard
On 1 June 2016
0 Comments
Base Erosion and Profit Shifting (BEPS), BEPS, BEPS Action 15, BEPS Multilateral Instrument, Tax Treaty

Canada Signs the Multilateral Competent Authority Agreement for the Automatic Exchange of Country-by-Country Reports

The OECD indicated yesterday: “As part of continuing efforts to boost transparency by multinational enterprises (MNEs), Canada, Iceland, India, Israel, New Zealand and the People’s Republic of China signed today the Multilateral Competent Authority agreement for the automatic exchange of Country-by-Country reports (“CbC MCAA”), bringing the total number of signatories to 39 countries. The signing […]

Posted by Robert Robillard
On 12 May 2016
0 Comments
Base Erosion and Profit Shifting initiative, BEPS Action 13, CbC reporting, Multilateral Competent Authority Agreement, Multilateral Convention on Mutual Administrative Assistance in Tax Matters, OECD Country-by-country reporting

Australia: Diverted Profits Tax Coming Soon

What the BEPS? Tax litigation growth, if nothing else… Significant increase of double tax cases, likely… Some readers will remember that Australia and the UK had formed a “joint working group” last year to explore, among other things, the relevance of the diverted profits tax. The government of Australia recently released a consultation paper titled […]

Posted by Robert Robillard
On 11 May 2016
0 Comments
Addressing Base Erosion and Profit Shifting, Australia diverted profit tax, Base Erosion and Profit Shifting (BEPS), BEPS, BEPS Australia, BEPS Canada, Diverted Profit Tax, UK Diverted Profits Tax

CRA’s Efforts to Combat Tax Avoidance and Evasion

On May 3rd and 5th, the Standing Committee on Finance (Parliament of Canada) conducted some interesting hearings on alleged international tax avoidance and evasion. These hearings can be viewed at length (4 hours) here : http://www.parl.gc.ca/Committees/en/FINA Both tax practitioners and CRA officials were asked to provide their perspective on the matter at hand. Once again, tax complexity, […]

Posted by Robert Robillard
On 9 May 2016
0 Comments

WCO: New Instrument on Transfer Pricing and Customs Valuation

The World Customs Organization explains: “The case study illustrates a scenario where Customs took into account transfer pricing information in the course of verifying the Customs value.” The 4-page case study is available here. Robert Robillard, Ph.D., CPA, CGA, Adm.A., MBA, M.Sc. Econ., M.A.P. Senior Partner, DRTP Consulting Inc. 514-742-8086; robertrobillard “at” drtp.ca www.drtp.ca The convergence of […]

Posted by Robert Robillard
On 6 May 2016
0 Comments
World Customs Organization

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