Increased Focus on Country-by-Country (CbC) and Other Reporting Measures
- Bulgaria introduces public CbC reporting rules requiring large MNEs to publish a CbC report locally.
- Moldova approved multilateral agreement for exchange of country-by-country reports, indicating future implementation.
- EU Commission recommends amendments to agreements with Andorra, Lichtenstein, Monaco, San Marino, and Switzerland to align with updated CRS standard.
Expansion in Information Sharing for Offshore Tax
- Guernsey ratifies protocol expanding automatic exchange of information with Montserrat.
- Singapore updates lists of reportable and participating jurisdictions for CRS.
- New Zealand updates list of participating jurisdictions for CRS with addition of 9 more countries.
Transparency Rising Scrutiny and Enforcement in Transfer Pricing and Anti-Avoidance
- Denmark court sentences individual to prison term for multi-million dividend fraud.
- UK publishes stats showing increase in transfer pricing related enquiries and assessments over last 5 years.
Revisions in Loss Carry Forward Rules After Ownership
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Sweden consulting on relaxing conditions and increasing deductible amounts for loss carry forwards after acquisitions.
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Italy extends deadline for submission of year one reports under new tax losses carry forward rules, indicating early phase challenges.
Change Emerging Focus on Intellectual Property Development Incentives
- Canada launches consultation on improving R&D incentives and introducing patent box regime.