On June 15, 2017, U.K. HMRC issued updated guidance on the Worldwide Disclosure Facility (WDF). See BEPS Action 12. On December 31, 2015, all HMRC offshore facilities closed. The WDF is currently available to anyone who would like to disclose a U.K. tax liability that relates wholly or partly to an offshore issue, which includes […] … Read More

On July 10, 2017, the OECD released its 2017 version of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (“TP Guidelines”), which provide guidance on the application of the arm’s length principle.  The TP Guidelines define the “arm’s length principle” as “the international standard that OECD member countries have agreed should be […] … Read More

On April 28, 2017, France issued Decree No. 2017-672, ratifying the OECD Multilateral Competent Authority Agreement for the Automatic Exchange of CbC reports (“CbC MCAA”), which was signed in Paris on January 27, 2016. On October 1, 2016, France implemented the CbC reporting requirements introduced in the 2016 Finance Act, which will apply for fiscal […] … Read More

On June 7, 2017, the OECD held a signing ceremony for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (“MLI”).  See BEPS Action 15.  67 countries and jurisdictions signed the MLI and eight jurisdictions have expressed their intent to sign. The OECD expects an additional 25-30 countries to sign the MLI. Approximately 1,100 tax treaties will be […] … Read More