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Approved Changes (1)
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OECD Releases Further Guidance on Country-by-Country Reporting (BEPS Action 13)

The OECD has released an Update as of July 18, 2017 to the Guidance on Implementation of Country-by-Country Reporting:  BEPS Action 13.  

The update addresses two issues:

  • How to treat an entity owned by two or more MNE Groups:  The New Guidance looks to follow the applicable accounting rules in whether to consolidate an entity into the financial consolidation of the MNE or not. If applicable accounting rules provide for consolidation, then the entity should also be consolidated for CbC reporting purposes. Similarly when pro-rata consolidation is applied by the applicable accounting rules, a pro-rata share of the entity's revenue may be allowed in applying the 750m Euro threshold and in determining the MNE's CbC financial data.
  • Whether Aggregated Data are to be Reported in Table 1:  The New Guidance provides that where there is more than one constituent entity in a jurisdiction, the model legislation contemplates that all constituent entities within that jurisdiction report on an aggregate basis. Allowance is made to allow some flexibility during a short transition period (i.e. for fiscal years starting in 2016) to allow time for MNE's to make necessary adjustments in applying this New Guidance.

Click the following for the full text of the OECD Country-by-Country Reporting Guidance Updated 18 July 2017.

Treaty Changes (5)

Bangladesh-Sri Lanka

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Bangladesh and Sri Lanka to Update Tax Treaty

As part of a three-day visit to Bangladesh, Sri Lankan President Maithripala Sirisena and Bangladesh Prime Minister Sheikh Hasina issued a joint statement expressing "deep satisfaction" on signing many instruments of cooperation in areas of mutual interest.

To promote economic partnership, the leaders called for authorities in both countries to quickly finalize updates to the Bangladesh - Sri-Lankan 1986 Income Tax Treaty.   Additional developments will be reported as they occur.

Barbados-Switzerland

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Barbados and Switzerland to Consider Tax Treaty Update

According to reports, in recent meetings in Bridgetown with officials from Switzerland, Barbados expressed interest in an update to the Barbados / Switzerland 1963 Income Tax Treaty.  Additional details will be provided as they occur.

Ecuador-Belarus

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Ecuador Approves Pending Tax Treaty with Belarus

On 13 July 2017, the the National Assembly of Ecuador approved the pending Income Tax Treaty with Belarus. The treaty, signed 27 January 2016, will enter into force after the ratification instruments are exchanged. Additional details will be published once available.

Saudi Arabia-Switzerland

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Saudi Arabia and Switzerland Discuss Possibility of Signing Double-Tax Treaty

According to a release from the Federal Department of Economic Affairs, Education and Research, Switzerland's Federal Councillor Johann N. Schneider-Ammann visited Saudi Arabia and met with Saudi Arabia ministers for a working session. Among other economic discussions, the possiblity of signing the Income Tax Treaty was raised. Treaty Negotiations go back several years. Any resulting treaty would be the first of its kind between the two countries, and must be finalized, signed, and ratified before entering into force.

Singapore-Switzerland

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Singapore and Switzerland Sign Competent Authority Agreement for Exchange of Tax Information

The Swiss government announced that in the margins of a Global Forum meeting in Geneva, Swiss Ambassador Alexander Karrer, deputy secretary of state of the SIF, and Singapore Deputy Commissioner of the Inland Revenue Authority Mrs. Huey Min Chia-Tern signed a bi-lateral automatic exchange of information agreement in tax matters (AEOI). This agreement was signed on 17 July 2017 and will be applied provisionally from January 1, 2018 with the first exchange of data in 2019. The agreement is subject to approval by the Swiss Parliament. With this latest agreement, Switzerland's network of bilateral CAAs relating to the exchange of financial account information now covers 52 jurisdictions.

Click the following for the press release.

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