Alerts

£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

Alerts

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

Alerts

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

Alerts

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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Transfer pricing audits: Coming soon in the Philippines

Alerts

Tax audits in The Philippines may soon be seeing some changes. For many years now, the tax authorities (Bureau of Internal Revenue or the “BIR”), taxpayers and tax practitioners have responded to...

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ATO releases initial CbC reporting guidance for Australian companies

Alerts

The ATO has released some initial guidance on the application of the new Country-by-Country reporting rules in Australia. The rules will apply from 1 January 2016 and impact all multinational groups...

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