Are you impacted by the new transfer pricing guidelines on financial transactions?

Background On 11 February 2020, the Organization for Economic Co-operation and Development (OECD) published its final guidelines on financial transactions as part of a newly added Chapter X. The first draft was published on 7 September 2018 in light of the 2015 report on BEPS Actions 8-10, which mandated follow-up to the transfer pricing aspects of financial […]

Why Debt-to-Equity analysis should be on your “Black Swan” radar?

What exactly is it?  A debt-to-equity (D/E) analysis determines if the forecasted debt level and capital structure of a company meet the arm’s length standard. In other words, it aims to establish an approximation of conditions that are consistent with third-party behavior. As a simplified illustration, here are just some of the typical transfer pricin […]

How BEPS 2.0 unified approach will revolutionize business models

With its new proposal (published October 9), the OECD tries to answer one burning question: How can profits and corresponding taxing rights on cross-border activities performed by multinationals be (re)allocated to cope with the ever-changing business models of the 21st century? The OECD’s objective is to build a consensus by the end of 2020 on interna […]

BEPS 2.0: The corporate tax revolution for international business is here!

The last few years have seen some big changes in the corporate tax world – from ATAD1 & 2 and the EU Commission’s anti-tax avoidance package to the recent US tax reform. The impact of these new rules has not gone unnoticed in many countries now subject to significant changes, and often harsher tax principles. This is just a drop in the ocean, howeve […]

All about Luxembourg’s new intellectual property regime

Luxembourg has recently enacted a new intellectual property (IP) regime in line with the OECD recommendations for more tax transparency, and in June an administrative circular was issued to help clarify this regime. The new IP regime aims to promote R&D activities largely performed in Luxembourg and offers, to Luxembourg taxpayers, an 80% tax exemption on el […]

Mandatory Disclosure Rules: five key questions for insurers

The Mandatory Disclosure Rules (MDR) arose from the ambitious anti-tax avoidance project on Base Erosion and Profit Shifting (BEPS) that the OECD launched in 2015. The MDR Directive, also known as DAC 6, is the latest EU initiative regarding the automatic exchange of tax information. Aimed at identifying harmful tax practices and further increasing tax transp […]