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.
Insights:
We’re seeing tax authorities collaborating more closely to plug information gaps (CRS expansion), while also aggressively investigating profit shifting risks (more inquiries). This ‘closed economy’ approach means enhanced reporting in return for benefits like incentives and flexible compliance. Companies may need internal coordination between tax, legal and government relations teams to track reporting changes, while also influencing policy-making through industry representations.
