Apart from the expectations surrounding the 5th October release of the OECD BEPS Action Items, the referenced EY Global Tax Alert provides relevant details for the following BEPS related activities:
- Australia: Multinational anti avoidance law (MAAL), transfer pricing documentation
- Belgium: Payments to “tax haven” jurisdictions
- Bulgaria: Consultation draft re: the EU Parent Subsidiary Directive; although the broader local GAAR would be retained
- China’s recent developments (refer to my 26 Sept. post)
- Denmark: Transfer pricing documentation
- Japan: Court case re: PE and “preparatory or auxiliary” exception
- Kuwait: Virtual Service PE interpretation (refer to my 23 Sept. post)
- NL: Transfer pricing doucmentation
The latest developments, along with future unilateral actions that follow the intent of the new OECD Action Items, should be monitored closely. Â Additionally, such concepts should be reviewed for domestic legislative compliance, vs. intent.
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