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EU Directive on Administrative Cooperation (DAC4)
The EU Directive on Administrative Cooperation (DAC4) introduced Country-by-Country Reporting (CBCR) to enhance tax transparency within the European Union. This amendment to the original DAC directive was implemented in 2016 through Council Directive 2016/881/EU.Key aspects of DAC4 include: DAC4 aims to combat tax evasion and avoidance by providing tax authorities with a comprehensive view of multinational…
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Section 29b of the Corporate Income Tax Act (Wet op de Vennootschapsbelasting 1969)
Section 29b of the Dutch Corporate Income Tax Act (Wet op de Vennootschapsbelasting 1969) relates to transfer pricing documentation requirements in the Netherlands. Specifically, it is part of the legislation that implements Country-by-Country (CbC) reporting, Master File, and Local File requirements for multinational enterprises (MNEs).Key points about Section 29b include: These requirements are part of the…
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Country-by-Country Reporting (CbCR) Regulation in the Netherlands
The Netherlands has established Country-by-Country Reporting (CbCR) requirements as part of its commitment to the OECD’s BEPS (Base Erosion and Profit Shifting) Action 13 framework. These regulations are overseen by the Dutch Tax and Customs Administration (Belastingdienst) and aim to ensure tax transparency and prevent profit shifting by multinational enterprises (MNEs). This guide provides key…
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Act on Special Measures Concerning Taxation (Japan)
The Act on Special Measures Concerning Taxation is an important piece of legislation in Japan that provides special tax measures and regulations. Here are the key aspects of this act: Purpose and Scope The Act on Special Measures Concerning Taxation (Act No. 26 of 1957) is a Japanese law that establishes special provisions related to…
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Country-by-Country Reporting (CbCR) Regulation in Japan
Japan has implemented Country-by-Country Reporting (CbCR) requirements under the OECD’s BEPS (Base Erosion and Profit Shifting) Action 13. The Ministry of Finance and the National Tax Agency (NTA) enforce these requirements to enhance transparency for multinational enterprises (MNEs) operating in Japan. This guide provides financial directors with key information on CbCR obligations in Japan, including…
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Guidance on Country-By-Country Reporting in Canada
In October 2015, the Organisation for Economic Co-operation and Development (OECD)/G20 project on Base Erosion and Profit Shifting (BEPS) issued reports in 15 action areas. One of these reports deals with Transfer Pricing Documentation and Country-by-Country ReportingFootnote3 (the BEPS Action 13 Final Report). The BEPS Action 13 Final Report recognized that enhancing transparency for tax administrations, by…
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Section 233.8 of the Income Tax Act (Canada)
Section 233.8 of the Income Tax Act in Canada pertains to Country-by-Country (CbC) reporting requirements for multinational enterprise (MNE) groups. Here are the key aspects of this section: Definitions The section begins by defining important terms: Reporting Obligations The reporting requirements under this section apply to: Purpose and Use of CbC Reports The CbC reports…
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Country-by-Country Reporting (CbCR) Regulation in Canada
Canada’s Country-by-Country Reporting (CbCR) requirements are aligned with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 framework. The legislation, overseen by the Canada Revenue Agency (CRA), mandates multinational enterprises (MNEs) with significant operations in Canada to provide transparent financial information. This guide details the requirements and implications of Canada’s CbCR rules, including applicability,…
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The strategic importance of large sales in company growth and its sustainability
Large sales play a vital role in the growth, stability, and long-term success of a company. While regular, smaller sales are essential for sustaining cash flow, major sales and high-value deals can be transformative. They not only generate significant revenue but also boost a company’s market position, create opportunities for operational expansion, and foster customer…
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Country-by-Country Regulation in Belgium
Belgium has implemented the Country-by-Country Reporting (CbCR) requirements in line with the OECD’s BEPS Action Plan, specifically following Action 13 on transfer pricing documentation. The regulation is enforced by the Belgian Federal Public Service (FPS) Finance, which oversees MNE compliance with CbCR obligations. This guide provides finance directors of multinational enterprises (MNEs) operating in Belgium…
