World Wide Tax News - Issue 40

On 27 January 2016, 31 countries signed a Multilateral Competent Authority Agreement (MCAA) that will require them to automatically exchange country-by-country reports (CbCR) that they collect from parent entities of multinational companies.

Data must be exchanged with other signatory jurisdictions in which the relevant entity has a presence within 18 months of the end of the relevant year. The first relevant year is 2016, so the first reports must be made by 30 June 2018.

Contents:

• INTERNATIONAL: Automatic exchange of CbCR to start with 31 countries
• EUROPEAN UNION: Corporate tax anti-avoidance package
• HONG KONG: Wooing multinationals - Tax initiatives bolster Hong Kong's position as a financial services centre
• INDIA: Start-up India action plan / Report of committee for income tax simplification / Place of effective management
• SINGAPORE: E-commerce - Singapore's approach
• BELGIUM: Belgium fully committed to implementing BEPS action plan
• FRANCE: Adjustments of the favourable regime for distributions received by parent companies / Changes to the dividend distribution regime under the French consolidated regime / Adoption of a Country-by-Country Transfer Pricing Reporting (CbCR) requirement
• IRELAND: Finance Act 2015 and Budget 2016
• ITALY: Changes to rules on taxation of cross-border relationships and latest updates
• KAZAKHSTAN: Special economic zones
• KOSOVO: Changes in Kosovo tax legislation
• POLAND: Changes in the Polish tax environment
• SERBIA: Amendments to the VAT law
• SPAIN: FATCA agreement between Spain and United States - Competent Authority Arrangement - enters into force / Spain and Mexico - Amended tax treaty
• SWITZERLAND: Calculation of hidden equity - Functional currency / Denial of withholding tax refunds in connection with derivative transactions (total return SWAPs)
• UNITED KINGDOM: Requirement to publish tax strategy documents
• CANADA: Non-resident employer certification program
• UNITED STATES: Major reforms to the foreign investment in Real Property Tax Act