Transfer Pricing Blog
Create and Manage your Intercompany Agreements
Multinationals are obliged to be in the possession of a list of ICAs (intercompany agreements), which serve as a supporting document to transfer pricing documentation and the tax position. TPGenie is recently updated with an inter-company agreements module. The module...
Submit your Country-by-Country Reporting to the Dutch tax authorities (Belastingdienst)
TPGenie is now ready for the electronic transmission of your BEPS Action 13 Country-by-Country reporting XML file to the tax authorities in The Netherlands (Belastingdienst) using WUS 2.0 Digikoppeling. As of January 1st, 2016, multinational groups with a turnover of...
Country-by-Country Reporting (CbCR) Excel to XML conversion Tool
Our software solution TPGenie is ready for generating your BEPS Action 13 Country-by-Country reporting in the XML format according to specifications of the OECD and affiliated countries. It is a very user-friendly solution for converting Excel to CbCR XML. You can...
Tax Technology Event 2017 – From ‘Staying Out Of Trouble’ To ‘Being In Control’
Thursday, 7 September 2017 Time: 9.00am – 4.00pm Amsterdam (CET) Venue: Marriott Courtyard Amsterdam Airport Hotel In the post-BEPS era, a surge in the number of deadlines to meet has led to an increase in the compliance burden. This, coupled with escalating disputes...
OECD releases peer review documents for assessment of BEPS minimum standards (Actions 5 and 13)
On February 1, 2017, the OECD released key documents, approved by the Inclusive Framework on BEPS, which will form the basis of the peer review of Action 13 Country-by-Country Reporting and for the peer review of the Action 5 transparency framework. The Action 13...
Deputy Minister of Finance releases new Transfer Pricing Decree
On May 11, 2018, the Dutch Deputy Minister of Finance published a new Transfer Pricing Decree, dated April 22, 2018 (no. 2018-6865). This decree replaces the Transfer Pricing Decree of November 14, 2013 (no. IFZ 2013/184M). The 2015 OECD BEPS Actions Plans and update...
31 countries sign tax co-operation agreement
As part of continuing efforts to boost transparency by multinational enterprises (MNEs), on 27 of January 2016 31 countries signed the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Country-by-Country reports. The signing ceremony...
BEPS Action 13 on Country-by-Country Reporting – The Netherlands
Country-by-Country Reporting On September 15 the Dutch government presented its plans to incorporate the proposed guidance of BEPS Action 13 on Country-by-Country Reporting. These plans include the obligation for Netherlands based multinational enterprises (MNEs)...
BEPS, The Latest OECD Release: Guidance on Transfer Pricing Documentation and Country-by-Country Reporting
The OECD has provided guidance on the transfer pricing documentation structure comprising of the following 3 documents: Master file – Providing a general overview if the MNE and its business activities ( in general applicable to all entities within the MNE); Local...
Can one rely on APA in US? Eation Corp is challenging the Internal Revenue Service in U.S. Tax Court
Eation Corp is challenging the Internal Revenue Service in U.S. Tax Court, arguing that the agency broke agreements dealing with how the company moves assets and money across international borders. Eaton is contesting a $75 million tax bill that the IRS imposed on the...