Alerts

1 September 2017 marks the start of the Country by Country reporting procedure in the UK. What’s next?

Alerts

After a long build up Country-by-Country reporting (‘CbCr’) procedure hits the ground in the United Kingdom. 1st September 2017 marks the first notification deadline for the UK tax resident...

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Richard Slimmen and Johann Muller of Quantera Global to attend IFA Brazil

Alerts

From 27 August to 1 September, the International Fiscal Association will host its 71st Congress in Rio de Janeiro, Brazil. Richard Slimmen and Johann Muller, Managing Directors of Quantera Global,...

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A practical summary of the July 2017 OECD Transfer Pricing Guidelines

Alerts

How many of us still have time to read 600+ page guidelines? How many of us have time to take those guidelines and combine them with chapters adopted after the guidelines were published? How does a...

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TURKEY INTRODUCING OECD’S COMMON REPORTING STANDARD

Alerts

The Turkish National Assembly has recently passed a law ratifying the Convention on Mutual Administrative Assistance in Tax Matters. The OECD has also issued a notification that Turkey is the 88th...

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£107 million Diverted Profit Tax charge to Diageo: Is it a tax?! Is it a penalty?! Or is it proof that HMRC has superpowers…

Alerts

On May 10, Diageo, a FTSE 100 alcoholic beverage company, reported that it will have to pay a Diverted Profit Tax charge of £107 million in relation to a period of just 15 months. This evidences the...

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Major developments for taxpayers in Indonesia

Alerts

A new Ministry of Finance (“MOF”) Regulation No. 213/PMK.03/2016 (“MoF-213”), which was issued and became effective on 30th December 2016, will have profound transfer pricing implications for...

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New Luxembourg Circular providing guidance for the tax treatment of intra-group financial transactions

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Introduction On December 27, 2016, the Luxembourg Tax Authorities issued a new Circulaire (“the Circular”) providing guidance for the tax treatment of intra-group financial transactions. The...

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Country-by-country reporting: extension first notification in Netherlands

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Introduction As part of the implementation of BEPS Action 13, the Netherlands introduced a notification requirement in respect of country-by-country-reporting (“CbCR”). This notification...

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Vietnam’s new TP Decree – The road ahead

Alerts

Note: The following provides our insights on the draft of the Transfer Pricing Decree (“TP Decree”), dated 3 October 2016, which is published on the official website of the Ministry of Finance....

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Are you prepared for Nexus in the Netherlands?

Alerts

hier moet een afbeelding Following the BEPS Action 5, the Netherlands will implement new legislation for a revised innovationbox which is likely to enter into force on January 1, 2017 as...

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Exchange of tax rulings, a Dutch practice update

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Both the OECD/G20 and EU have introduced rules aimed at improving transparency on tax rulings granted by jurisdictions. As part of the outcomes of Action 5 of the OECD/G20 BEPS Project, a framework...

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Country-by-Country reporting requirements in Australia

Alerts

In December 2015, Parliament passed the Tax Laws Amendment (Combating Multinational Tax Avoidance) Bill 2015, which included Australia’s new Country-by -Country Reporting (“CbCR”) rules. The...

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