Depreciation of goodwill and freedom of establishment
Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on tax treaty developments, including trends influenced by BEPS.
OECD recommendations hailed as ‘important milestone’, and the challenge now is to ensure measures are implemented consistently and coherently.
The OECD has provided further details regarding the release of its final recommendations on BEPS on Monday 5 October.
The European Commission has published responses to the public consultation on further corporate tax transparency.
The EU Joint Transfer Pricing Forum (JTPF) has agreed on its programme of work for the period 2015–2019. The programme of work will consist of monitoring and improving the existing JTPF guidance and developing new tools and guidance where appropriate.
The IRS has confirmed that the US has signed competent authority arrangements (CAA) with Australia and the UK, these are the first arrangements of this kind to be signed and it is anticipated that CAAs with other intergovernmental agreement (IGA) jurisdictions will be signed in the near future.
The European Commission has published a report on analysing tax policy challenges and recent reforms in member states. The report is intended to contribute to discussions on tax policy in the EU. See www.bit.ly/1FD0owj.
The governments of the UK and Japan have published a memorandum of understanding setting out the arbitration process under art 25 of the 2006 double taxation convention, as amended by the 2014 protocol with effect from 12 December 2014.
China has published a discussion draft Implementation measures for special tax adjustments which would comprehensively revise circular 2, China’s main transfer pricing guidance.