Weekly transfer pricing roundup – 28 November

working_together_teamwork_puzzle_conceptI forgot how much time it takes to prepare, present and participate at a TP Summit and still continue with the normal work and personal life. But yes, I managed. I blogged about all the highlights and juicy moments earlier this week, if you haven’t had the chance to read them yet, do yourself a favour and go there now… or wait, maybe read this blog first and then read the TP Summit ones.

The latest developments worth a read are summarised below including an update on BEPS Action Point 15, as always for the full story follow the links in the headings.

Countries adopt multilateral convention to close tax treaty loopholes and improve functioning of international tax system (OECD)

“More than 100 jurisdictions have concluded negotiations on a multilateral instrument that will swiftly implement a series of tax treaty measures to update international tax rules and lessen the opportunity for tax avoidance by multinational enterprises.

The new instrument will transpose results from the OECD/G20 BEPS into more than 2 000 tax treaties worldwide. A signing ceremony will be held in June 2017 in Paris.

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS will implement minimum standards  to counter treaty abuse and to improve dispute resolution mechanisms while providing flexibility to accommodate specific tax treaty policies. It will also allow governments to strengthen their tax treaties with other tax treaty measures developed in the OECD/G20 BEPS Project…”

Transfer pricing: ‘Days of pleading ignorance are over’ (Moneyweb)

“JOHANNESBURG – The days where large multinational companies could plead ignorance with regard to transfer pricing practices are over and firms should gear up for close scrutiny, a tax expert has warned.

Speaking at the 5th Annual Africa Transfer Pricing Summit, Sunita Manik, senior executive for transfer pricing at Baker & McKenzie and former member of the Sars executive committee, said the days where the tax support function merely had to take responsibility for compliance documents without understanding the business were long gone…”

Macau, Mauritius, Ukraine join the ‘inclusive framework on BEPS’ to combat multinational tax avoidance (MNE Tax)

“Macau, Mauritius, and Ukraine have joined the ‘inclusive framework on BEPS,’ a group of countries that have pledged to promote the implementation of measures to combat multinational tax avoidance designed by the OECD and G20 in the BEPS project.

Total membership of the inclusive framework on BEPS now stands at 90 countries and jurisdictions, including 44 non-OECD/non-G20 countries…”

Formula 1 could face EC tax investigation (Motorsport.com)

“Formula 1 could face a European Commission tax investigation after it emerged this weekend that it had avoided paying at least $500 million (USD) in tax over the past decade through clever practices.

A report in The Mail on Sunday revealed that F1’s companies paid just $6.5 million in corporation tax – on profits of $463.6 million from revenue of $1.7 billion.

This is a tax rate of just 3.3 percent – nearly eight times lower than businesses are supposed to pay…”

Netherlands: CbCR notification term extended till September 1, 2017 (Grant Thornton)

“The State Secretary of Finance announced, on November 17, that the term for the Country-by-Country notification obligation regarding Dutch parent entities, surrogate parent entities and other Dutch group entities to the Dutch tax authorities has been extended to September 1 2017…”

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