OECD releases BEPS discussion drafts on PE profits attribution & transactional profit splits

OECD releases new/revised BEPS discussion drafts on PE profits attribution, transactional profit splits; Revises drafts issued in July 2016.

Jun 22, 2017

Australia issues draft risk-based compliance guideline for related party financing arrangements

Australian Taxation Office (‘ATO’) issues a draft practical compliance guideline which sets out its administration approach in respect of cross-border (inbound and outbound) related party financing arrangements; The guideline provides

May 24, 2017

America executes 86 APAs in 2016, Indian bilateral applications dominate US filings

US IRS issues statutory report on Advance Pricing and Mutual Agreement Program (APMA Program) for calendar year 2016, highlights signing of 86 APAs (21 unilateral and 65 bilateral); 34% of

Apr 03, 2017

New Zealand proposes interest rate cap on related loans, rule targeting PE avoidance

New Zealand releases 3 discussion documents seeking submissions on a package of measures to counter BEPS, namely, i) Transfer pricing and permanent establishment (“PE”) avoidance, ii) Strengthening interest limitation rules

Mar 14, 2017

New Zealand to incorporate BEPS Actions 8-10 revisions to align TP-rules with economic substance

New Zealand releases discussion document proposing to introduce a package of measures, in addition to other BEPS related measures, to address transfer pricing (TP) and permanent establishment (PE) avoidance; In

Mar 10, 2017

Public CbCR to require qualified majority rather than unanimity : European Parliament

European Parliament’s Committee on Legal Affairs issues public opinion on legal basis of EC proposal relating to public Country-by-Country (CbC) reporting; Concludes that the introduction of public CbCR being an

Feb 20, 2017