How Donald Trump’s tax plan is already creating jobs in the US

2018-02-09T07:17:17+00:00

How Donald Trump’s tax plan is already creating jobs in the US.  There is no doubt in my mind that the Trump tax plan, specifically the reduction in the corporate tax rate from 35% to 21%, will new create jobs in the US. I know this because I already have clients and [...]

How Donald Trump’s tax plan is already creating jobs in the US 2018-02-09T07:17:17+00:00

How To Reduce Your Tax By Investing In Start-Up `s

2018-02-09T10:43:27+00:00

How To Reduce Your Tax By Investing In Start-Up `s If you’re an investor or a start-up looking for an investor, you may have heard that the government has introduced a new tax break for investors investing in start-ups. The way it works is fairly straightforward:  invest is a [...]

How To Reduce Your Tax By Investing In Start-Up `s 2018-02-09T10:43:27+00:00

BEPS Action 15 – Develop a Multilateral Instrument

2018-02-11T17:21:27+00:00

BEPS Action 15 - Develop a Multilateral Instrument BEPS Action 15 “Developing a multilateral instrument to modify bilateral treaties” aims to develop a multilateral instrument to enable jurisdictions to implement measures developed in the course of the work on BEPS and to amend bilateral tax treaties. The multilateral instrument [...]

BEPS Action 15 – Develop a Multilateral Instrument 2018-02-11T17:21:27+00:00

BEPS Action 14 – Dispute Resolution Mechanisms

2018-02-11T17:34:50+00:00

BEPS Action 14 - Dispute Resolution Mechanisms BEPS Action 14 “Making dispute resolution mechanisms more effective” notes that countries have agreed on a minimum standard and a number of best practices in relation to dispute resolution. A group of 20 States, including Australia, France, Germany, Italy, Luxembourg, Spain, the [...]

BEPS Action 14 – Dispute Resolution Mechanisms 2018-02-11T17:34:50+00:00

BEPS Action 13 – Transfer Pricing Documentation

2018-02-11T17:55:35+00:00

BEPS Action 13 - Transfer Pricing Documentation BEPS Action 13 “Transfer pricing documentation and Country-by-Country Report includes revised guidelines on transfer pricing documentation and Country-by-Country Reporting (CBCR). In particular, the Final Report on Action 13 proposes a three tiered documentation structure: A master file containing high-level information regarding global business [...]

BEPS Action 13 – Transfer Pricing Documentation 2018-02-11T17:55:35+00:00

BEPS Action 12 – Disclosure of Aggressive Tax Planning

2018-02-11T18:13:47+00:00

BEPS Action 12 - Disclosure of Aggressive Tax Planning BEPS Action 12 “Mandatory disclosure rules” aims to require taxpayers to disclose their aggressive tax planning arrangements. This will be addressed through the development of recommendations regarding the design of mandatory disclosure rules for aggressive or abusive transactions, arrangements, or structures, [...]

BEPS Action 12 – Disclosure of Aggressive Tax Planning 2018-02-11T18:13:47+00:00

BEPS Action 11 – Measuring and Monitoring BEPS

2018-02-11T18:26:32+00:00

BEPS Action 11 - Measuring and Monitoring BEPS BEPS Action 11 “Measuring and monitoring BEPS” aims to establish methodologies to collect and analyse data on BEPS and the actions to address it. The OECD intends to do this by developing recommendations regarding indicators of the scale and economic impact [...]

BEPS Action 11 – Measuring and Monitoring BEPS 2018-02-11T18:26:32+00:00

BEPS Actions 8-10 – Align Transfer Pricing Outcomes with Value Creation

2018-02-12T02:51:31+00:00

BEPS Actions 8-10 - Align Transfer Pricing Outcomes with Value Creation BEPS Actions 8-10, “Aligning Transfer Pricing Outcomes with Value Creation” includes new guidance on how to allocate transfer price risk, transfer price intangibles, hard-to-value intangibles (HTVI), commodities, low value-adding intra-group services and cost contribution arrangements. Specifically, the Final Report [...]

BEPS Actions 8-10 – Align Transfer Pricing Outcomes with Value Creation 2018-02-12T02:51:31+00:00

BEPS Action 7 – Artificially Avoiding PE Status

2018-02-12T03:03:46+00:00

BEPS Action 7 - Artificially Avoiding PE Status BEPS Action 7  “Preventing the artificial avoidance of permanent establishment status” contains agreed amendments to the definition of “permanent establishment” in Article 5 of the OECD Model Tax Convention, which is widely used as the basis for negotiating tax treaties. These changes [...]

BEPS Action 7 – Artificially Avoiding PE Status 2018-02-12T03:03:46+00:00

BEPS Action 6 – Prevent Treaty Abuse

2018-02-12T03:15:19+00:00

BEPS Action 6 - Prevent Treaty Abuse BEPS Action 6 “Preventing the granting of treaty benefits in inappropriate circumstances” recommends that countries include in their tax treaties an express statement that their common intention is to eliminate double taxation without creating opportunities for treaty shopping. The Final Report on BEPS [...]

BEPS Action 6 – Prevent Treaty Abuse 2018-02-12T03:15:19+00:00