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On January 20, 2016 the Swiss Government issued a press release announcing that it approved the signing of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (Hereafter the Agreement). According to the press release Switzerland as well as numerous other countries are going to sign the Agreement in Paris on January 27, 2016.

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Based on the overview of Jurisdictions Participating in the Convention on Mutual Administrative Assistance in Tax Matters as available on the website of the OECD, on January 20, 2016 Singapore deposited its instrument of ratification, acceptance or approval for the OECD’s Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Singapore signed the Amended Convention on May 29, 2013.

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The Australian Taxation Office (ATO) has made LCG (Law Companion Guideline) 2015/3 – Subdivision 815-E of the Income Tax Assessment Act 1997: Country-by-Country reporting available on its website. According to an announcement made by the ATO in this respect, it developed the guideline in consultation with industry to help the public understand how the ATO will apply the Country-by-Country (CbC) reporting rules, which adopt the OECD's new transfer pricing documentation standards into Australian law.

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On January 18, 2016 the Canadian Department of Finance issued a press release announcing that on January 15, 2016 the Canadian Trade Office in Taipei and the Taipei Economic and Cultural Office in Canada signed an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (Hereafter: the DTA).

Although the DTA has been signed, it has not entered into force yet. For the DTA to enter into force, the respective ratification procedures have to have been finalized in both countries.

 

Below we will discuss a selection of provisions included in the DTA of which we think they might interest our readers.

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In today’s edition: Japan – Negotiations for Tax Convention with Slovenia Will Be Initiated; The Netherlands – Voorstellen voor vereenvoudiging van belastingwetgeving; Netherlands – Kamerbrief evaluatie bankenbelasting

  1. European Parliament: “Money that a member state should recover from a company due to infringements of tax-related state aid rules should be returned not to the same member state”
  2. IASB issues narrow-scope amendments to IAS 12 Income Taxes
  3. Hong Kong and Russia conclude a DTA
  4. The opinion of Advocate General Sharpston in Case C-546/14 Degano Trasporti has been published (VAT – Partial payment of a VAT debt to the Member State – Trader in financial difficulties – Arrangement with creditors)
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