Attached are the latest BEPS developments; of particular importance is the International ComplianceAssurance Programme (ICAP). This program is a voluntary program that focuses on the Country-by-Country (CbC) reports to openly discuss tax risks.
This is a welcome collaborative effort between the tax administrations and MNEs, vs. using the CbC reports to draw unfounded assumptions.
Tax audits should also use this approach at the beginning of an audit to foster understanding and risks.
Annual reviews are now being discussed, with employees wondering what technical goals and objectives lie ahead.
Most importantly, the art of leadership skills and training should be a required attribute on everyone’s agenda. There are books for self-learning, and also real-time training can be conducted via leading small cross-functional meetings, being a champion on projects for coordination, and team activities
Leadership and developing leadership skills, in addition to requisite technical abilities, are what will make the difference for everyone.
The Italian Budget has enacted a 3% web tax, and a new PE definition based on economic, vs. physical, presence.
The Tax is due by the buyers of the above services unless the supplier declares in the invoice that it has not reached the threshold of 3,000 transactions in the calendar year.
The PE definition goes beyond the OECD’s intent, and will certainly lead to additional disputes in Italy and other countries developing such a subjective measure that also attracts double taxation.
EY’s global tax alert provides additional details as reference.