Publications

Choices. Priorities. Opportunities. Finance Act 2016.

Finance Act 2016: Choices. Priorities. Opportunities.

An update on foreign direct investment activity in Ireland.

Investing in Ireland: Issue 29

PwC and World Bank Group Paying Taxes 2017 Report.

PwC / World Bank Group report: Paying Taxes 2017


Investing in Ireland: Issue 29
Ireland continues to achieve the highest rankings in a number of key FDI areas (see page 6), and PwC’s recent Paying Taxes global report shows Ireland is one of the most efficient countries for businesses paying taxes and tax compliance obligations.

An update on foreign direct investment activity in Ireland, issue 29.
January 2017

PwC / World Bank Group report: Paying Taxes 2017
This eleventh edition of Paying Taxes comes at a time when, with low commodity prices and continued weak economic growth, there is an increasing need to broaden tax bases, increase voluntary compliance and build tax capacity, particularly in developing economies.

2016 Finance Bill
November 2016

Investing in Ireland: Issue 28
An update on foreign direct investment activity in Ireland.

2016 Finance Bill
October 2016

Choices. Priorities. Opportunities. Finance Bill 2016
Finance Bill 2016, which implements the measures announced by Minister Noonan in last week’s Budget, contains a number of incremental measures aimed at improving existing reliefs, fostering entrepreneurship and easing the tax burden on individuals. It also includes measures which affect funds with interests in Irish real estate assets and limits for voluntary disclosure of liabilities relating to offshore income or assets.

2016 Finance Bill
October 2016

European Commission finds that Ireland has granted unlawful State aid to Apple
In its press release issued on August 30, 2016, the European Commission announced the adoption of its final decision in the formal State aid investigation into the profit attribution arrangements and corporate taxation of Apple in Ireland. The Commission concluded that, in its opinion, Apple benefitted from unlawful State aid granted by Ireland, and it orders full recovery of the aid in an amount of up to €13 billion plus compound interest.

European Commission finds that Ireland has granted unlawful State aid to Apple.
September 2016

Ireland introduces formal bilateral APA program
The Irish Revenue Commissioners have introduced a formal bilateral advance pricing agreement (APA) program which will be effective from July 1, 2016. Prior to this, Ireland accepted requests for bilateral APAs with treaty partners where invited to do so by the other country. The new program was introduced in response to Action 14 of the Base Erosion and Profit Shifting (BEPS) initiative with a view to providing certainty to taxpayers in relation to the taxation of cross-border transactions and is in line with OECD Best Practice Guidelines.

An Operational Manual has been issued by Irish Revenue which outlines the APA framework, governance, process, roles, responsibilities, and mutual expectations for taxpayers and the Irish authorities in applying for, negotiating, and concluding bilateral APAs.

Ireland introduces formal bilateral APA program.
September 2016

International tax news: September 2016
This monthly newsletter from PwC's International Tax Network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International tax news: September 2016
September 2016

International tax news: August 2016
International tax news is designed to help multinational organisations keep up with the constant flow of international tax developments worldwide.
Among the topics featured in this month's edition are:

  • Poland's draft bills to amend the CIT and PIT laws
  • China's new working guidelines for the administration and assessment of High and New Technology Enterprises (HNTEs)
  • The new Brazilian CFC rules
  • Retroactive changes to triangular brand rules in the US-Luxembourg treaty

International tax news: August 2016
August 2016

2016 CEO Pulse Survey
Finding success in an age of uncertainty

2016 CEO Pulse Survey
July 2016

Customs Insights – Duty Suspension Opportunity
With the deadline for duty suspension applications approaching this update highlights the opportunity for traders to benefit from cost savings.


Customs Insights – Duty Suspension Opportunity
July 2016

International tax news: July 2016
This monthly newsletter from PwC's international tax network provides an overview of international tax developments from countries worldwide.

Among the topics featured in this month's edition are:
  • Amendments to Singapore's Income Tax Act
  • Introduction of a new tax bill in New Zealand's parliament
  • New HM Treasury and HMRC Consultations from the UK
  • Dutch Court of Appeal rules in favour of a cross border fiscal unity with a non-EU parent



International Tax News: July 2016
July 2016

International tax news: June 2016
This monthly newsletter from PwC's international tax network provides an overview of international tax developments from countries worldwide.


International Tax News: June 2016
June 2016

Investing in Ireland: Issue 27
Ireland achieved “No.1” ranking again in a number of categories in the recently updated IMD World Competitiveness Yearbook 2016, with an overall increase of 9 places to 7th most competitive economy in the world.

Ireland continues to enjoy strong economic growth, having regained its Moody’s ‘A’ credit rating and with unemployment reaching the lowest level since 2008.

This issue also provides a snapshot of Ireland’s attractiveness for software engineering and summarises recent FDI investment announcements across various sectors.


Investing in Ireland: Issue 27
June 2016

International tax news: May 2016
This monthly newsletter from PwC's international tax network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International Tax News: May 2016
May 2016

European Commission proposes an EU Directive on public country-by-country reporting
The European Commission has developed a proposal for a directive which, if approved by the European Parliament and Council of Ministers, will require public country-by-country reporting (CbCR) of tax and other financial data by large companies in the European Union (EU). The proposed directive will amend the existing EU Accounting Directive.

This paper summarises the contents of the draft directive on public CbCR with our thoughts on some of the key issues.

European Commission proposes an EU Directive on public country-by-country reporting
April 2016

International tax news: April 2016
This monthly newsletter from PwC's international tax network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International Tax News: April 2016
April 2016

International tax news: March 2016
This monthly newsletter from PwC's international tax network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International Tax News: March 2016
March 2016

Investing in Ireland: Issue 26
Ireland continues to enjoy strong economic growth with ongoing reductions in unemployment. A look at the labour market shows high levels of graduates in Ireland, with a focus on science and technology.

Ireland also again achieved “No.1” in recently updated global competitiveness rankings from IBM’s Global Location Trends and IMD’s World Competitiveness Yearbook and is recognised as having the most efficient and effective tax system among EU member states in the “Paying Taxes” report.

This issue also provides a snapshot on Ireland’s attractiveness for aviation leasing and summarises recent FDI investment announcements across various sectors.

Investing in Ireland: Issue 26
March 2016

The UK introduces country-by-country reporting
Final UK regulations mandate UK-parented multinational entities (MNEs) with annual consolidated group revenue of €750 million or more to comply with new transfer pricing and transparency requirements, with the first country-by-country report (CBCR) due for fiscal years beginning on or after January 1, 2016. In certain circumstances, UK group entities (other than UK-parented MNEs) also may be obliged to file CBCRs.
This Tax Insight outlines the new country-by-country requirements in the UK, including the alignment and inconsistencies with the OECD recommendations, and highlights some of the potential implications for UK taxpayers.

The UK introduces country-by-country reporting
March 2016

Tax facts 2016
This publication is a practical and easy-tofollow guide to the Irish tax system. It provides a summary of Irish tax rates as well as an outline of the main areas of Irish taxation.

Tax facts 2016
March 2016

OECD announces agreement on framework for broader participation in BEPS stage two
As we enter the second phase of the OECD-led Base Erosion and Profit Shifting (BEPS) project, the OECD has agreed a new framework that would, if approved, allow all interested countries and jurisdictions to become part of an inclusive dialogue on an equal footing. This dialogue would cover clarifications (and work left to complete on standard setting), implementation and monitoring. It would include, for developing countries, the development and provision of practical toolkits that address the top priority issues they have identified.

The involvement in standard setting of any non-OECD members that wish to sign-up on the specified terms is unprecedented in the tax area.

OECD announces agreement on framework for broader participation in BEPS stage two
February 2016

31-country agreement will effectuate exchanges of CbC reports
On January 27, 31 countries signed the, Multilateral Competent Authority Agreement (MCAA), allowing automatic exchange of Country-by-Country (CbC) reports described in Action 13 of the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Project. The MCAA is intended to facilitate consistent and swift implementation of new transfer pricing reporting standards developed under Action 13 of BEPS Action plan, with the goal of enabling tax administrations to obtain a complete understanding of how MNEs structure their operations, while also safeguarding the confidentiality of such information.

The MCAA outlines specific requirements, terms of use, and guidance for automatic exchange of CbC reports among its signatories. Importantly, it represents a significant achievement for the OECD with respect to implementation of Action 13 and cross-border cooperation on tax matters. The MCAA also reflects the concept underpinning Action 15, the multilateral treaty instrument, that the OECD should act on a multilateral basis with respect to implementation of the final BEPS reports, in order to avoid the time-consuming negotiation of bilateral agreements.

31-country agreement will effectuate exchanges of CbC reports
February 2016

International tax news: February 2016
This monthly newsletter from PwC's International Tax Network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International tax news: February 2016
February 2016

European Commission proposes anti-tax-avoidance package
The European Union (EU) Commission (EC) on January 28, 2016, presented an anti-tax-avoidance package (ATAP) that consists of seven sections, including a proposed anti-tax-avoidance directive (draft ATA directive). The draft directive outlines minimum standards based on proposals from the Organisation for Economic Co-operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) deliverables. The draft directive differs from corresponding BEPS proposals in some regards and covers additional subjects, such as exit taxation and a minimum level of taxation on third-country income. The ATAP will be subjected to political and technical discussions, and its enactment is uncertain. If it is enacted in some form, it is expected to significantly affect US companies investing in the EU.

European Commission proposes anti-tax-avoidance package
February 2016

BEPS Update
As we enter the second phase of the OECD-led BEPS project, which covers clarifications (and work left to complete), implementation and monitoring, we reflect on the changes and tax authority reactions following the 5 October 2015 release of the BEPS final reports. Governments and tax authorities have been very active, from both a behavioural and a legislative basis. This includes tax authorities in such countries as the United Kingdom, Australia, China and the United States, among others. Undoubtedly, the BEPS project has already had, and will continue to have, a profound impact for most taxpayers.
As part of extending the reach of the BEPS project, a 'framework' is to be agreed early in 2016 with involvement -- on an equal footing -- of interested countries and jurisdictions other than OECD members and G20 members. This will include input from supranational organisations like the UN, IMF and World Bank Group. The OECD and relevant working groups are currently addressing this action, along with other actions that were identified in the BEPS final reports presentation. We consider the framework and also look ahead to what likely will happen throughout 2016 and beyond. Finally, on an individual action-by-action basis, we add insights regarding the various stakeholders' intentions and commitments.

BEPS Update
January 2016

European Commission presents EU Anti-Tax Avoidance Package
A PwC summary of the recently released anti tax avoidance directive from the European commission.

European Commission presents EU Anti-Tax Avoidance Package
January 2016

Customs & International Trade Communiqué UCC edition
With the implementation of Union Customs Code (UCC) fast approaching (1 May 2016), this update gives an overview of some of the most important changes and covers AEO, BTI’s, Customs Procedures, Customs Valuation, Definition of Exporter & Non-Preferential Origin.

Customs & International Trade Communiqué UCC edition
January 2016

Paying Taxes 2016
Paying Taxes is a joint report by PwC and the World Bank Group. Now in its tenth edition it continues to be a unique study which investigates and compares tax regimes across 189 economies, ranking them according to the relative ease of paying taxes.

International tax news: January 2016
January 2016

International tax news: January 2016
This monthly newsletter from PwC's international tax network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International tax news: January 2016
January 2016

Finance Act 2015
Our specialists take a look at how Finance Act 2015 affects you, your business and Irish Tax Law.

Finance Act 2015
December 2015

Investing in Ireland: Issue 25
The positive tax changes announced in Budget 2016 should ensure that Ireland remains a competitive global location for existing and new FDI.
Ireland also again achieved “No.1” in recently updated global competitiveness rankings from IBM Global Location Trends and the IMD World Competitiveness Yearbook.
Other topics covered in this issue include the Directors’ Compliance Statement introduced in Companies Act 2014, increased investment in data centres and new air routes from Ireland to the US.

Investing in Ireland: Issue 25
December 2015

CEO confidence in Asia Pacific shaken but strong
After a year of historic foreign direct investment into developing Asian economies, CEOs have become hypersensitive to financial market signals. PwC surveyed 800 business leaders with operations in APEC’s 21 member economies between June 23 and August 21.

CEO confidence in Asia Pacific shaken but strong
December 2015

International tax news: December 2015
This monthly newsletter from PwC's international tax network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International Tax News: December 2015
December 2015

International Transfer Pricing 2015/16
An easy to use reference guide covering a range of transfer pricing issues in nearly 100 territories worldwide.

International Transfer Pricing 2015/16
November 2015

Update on EU Customs valuation under the UCC
With the implementation of Union Customs Code (UCC) fast approaching (1 May 2016), this update sets out some developments relating to the abolishment of first sale and the definition of transaction value, transitional arrangements, related party transactions and royalty payments.

Update on EU Customs valuation under the UCC
November 2015

Ireland introduces legislation to implement country-by-country reporting
The Irish Government on October 22 released Finance Bill 2015, which includes draft legislation introducing country-by-country (CbC) reporting for Irish-parented multinational enterprises (Irish MNEs). The draft legislation requires Irish MNEs with consolidated annualised group revenue of €750 million or more to comply with the new requirements, with the first CbC report to be prepared for fiscal years beginning on or after January 1, 2016.

Ireland introduces legislation to implement country-by-country reporting
November 2015

International tax news: November 2015
International Tax News provides a succinct monthly analysis of select legislative changes, case law and treaty news from around the globe.

International tax news: November 2015
November 2015

Transfer Pricing Perspectives: Beyond boundaries
A series of articles based on our Global Transfer Pricing Conference in Shanghai, China

Transfer Pricing Perspectives: Beyond boundaries
October 2015

Impact of BEPS on Domestic Groups

Investing in Ireland: Issue 24
October 2015

Investing in Ireland: Issue 24
Welcome to the 24th edition of PwC’s newsletter on foreign direct investment (“FDI”) in Ireland.
For the fourth consecutive year, Ireland has been ranked as the number 1 global FDI destination based on a range of metrics.
This is enhanced by the strong pipeline of recent Irish investments by new and existing investors across all sectors (see pages 2&3).
In this issue we highlight that confidence in Ireland’s economy and business is at an all-time high, as illustrated in PwC Ireland’s 2015 CEO Pulse Survey.
Other topics covered in this edition include a snapshot of new Irish GAAP rules regarding FRS 101 & 102, our proposed “Knowledge Development Box” and a selection of other FDI events and developments.

Investing in Ireland: Issue 24
September 2015

Global tax transparency and risk management
The new landscape prompts changes to operations, strategy and budgets.

Global tax transparency and risk management
September 2015

Revenue to target the construction sector
Revenue announced in a recent publication, it's intention to focus on tax compliance in the construction sector with a particular focus on Relevant Contracts Tax (RCT). This bulletin sets out the key risks for companies operating in the construction sector if subject to a Revenue intervention.

Revenue to target the construction sector
September 2015

PwC submission document on the tax treatment of expenses for Non-Executive Directors attending board meetings
In August 2015 PwC responded to the invitation from the Minister for Finance for submissions to be made to the Department of Finance as part of the consultation on the ‘Tax Treatment of Travel and Subsistence for Employees and Office Holders’. The focus of the submission was on the tax treatment of expenses for Non-Executive Directors (NEDs) attending board meetings.

PwC submission document on the tax treatment of expenses for Non-Executive Directors attending board meetings
August 2015

Taxing times for global business
Despite evidence that governments around the world are reducing tax costs and compliance, these efforts are not being felt by CEOs. Here we explore some of the reasons for the disparity.

Taxing times for global business
July 2015

International tax news: July 2015
This monthly newsletter from PwC's international tax network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International tax news: July 2015
July 2015

Global Research & Development Incentives Group

Global Research & Development Incentives Group
June 2015

Investing in Ireland: Issue 23
The strong pipeline of Irish investments by new and existing investors across all sectors continues in 2015, with Dublin being recognised as one of the world’s most vibrant cities.
In addition, the Harvard Business Review has also recently named Ireland as a ‘standout’ digital economy and all the leading FDI rankings continue to show Ireland as the number 1 global FDI destination based on a range of metrics.
This issue provides an overview of Ireland s very important economic relationship with the US, which has recently been recognised as the leading international export platform for US groups.
It also provides a snapshot of some recent developments in the people, mobility and reward space.

Turning disruption to advantage - DIMA Insurance Leaders Survey
June 2015

OECD releases model documents for implementing country-by-country reporting
On 8 June 2015, the OECD released a "Country-by-Country Reporting Implementation Package." The package includes model legislation the OECD suggests could be used by countries to mandate filing of country-by-country reports (CbCRs). The model legislation does not attempt to address the filing of the so-called master file or local file reports. The implementation package also includes three model competent authority agreements that could be used by each country, depending on how it intends to effect exchange of CbCRs.

OECD releases model documents for implementing country-by-country reporting
June 2015

European Commission’s Joint Transfer Pricing Forum mandate and new composition confirmed
On 12 May 2015, the Director-General for Taxation and Customs Union appointed the Members and the Chairperson of the EU Joint Transfer Pricing Forum (JTPF) for the next two year mandate starting on 1 April 2015 till 30 March 2017. For the first time since its set up in 2002, the European Commission has appointed organisations rather than individuals.
The new composition of the JTPF also includes non-governmental institutions alongside multinational enterprises, Professional Services Firms, industry organisations and government representatives of each Member State.

European Commission’s Joint Transfer Pricing Forum mandate and new composition confirmed
June 2015

OECD guidance on transfer pricing aspects of intangibles: hard-to-value intangibles
The OECD has published a discussion draft on the arm's length pricing of intangibles when valuation is highly uncertain at the time of the transaction or the intangibles are hard to value. The discussion draft, released 4 June 2015, is part of Action Item 8 of the OECD's Base Erosion and Profit Shifting (BEPS) Action Plan. Action Item 8 is focused on assuring that transfer pricing outcomes with respect to intangibles are in line with value creation.

OECD guidance on transfer pricing aspects of intangibles: hard-to-value intangibles
June 2015

International tax news: June 2015
This monthly newsletter from PwC's International Tax Network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International tax news: June 2015
June 2015

PwC India Indirect Tax & Customs newsletter: May 2015
This newsletter provides important judicial and legislative developments relating to service tax, central excise, VAT/CST, customs, foreign trade policy & WTO provisions in India

PwC India indirect tax & customs newsletter: December 2014
May 2015

Transfer pricing announcements in Australian Federal Budget
The Australian Government's 2015/16 Federal Budget released on 12 May contained several measures targeted at multinationals. The key announcements included:
  • A commitment to implement the new OECD transfer pricing documentation requirements, including country-by-country (CbC) reporting, from 1 January 2016.
  • Higher penalties for companies that enter into tax avoidance or profit shifting schemes.
  • A new anti-avoidance rule aimed at multinationals selling to Australian customers where the revenue and profits are booked by a non-resident under a structure that is designed to avoid creating a permanent establishment (PE) in Australia.
Other relevant announcements included the provision of additional funding to the Australian Taxation Office (ATO) for auditing transfer pricing and international tax issues under its International Structuring and Profit Shifting Project and taking steps towards adopting other actions from the OECD Base Erosion and Profit Shifting project such as anti-hybrid rules.

Transfer pricing announcements in Australian Federal Budget
May 2015

OECD releases revised base erosion and profit shifting proposals on permanent establishments
The OECD has released its revised proposals on the Permanent Establishment (PE) rules in Article 5 of the OECD Model Tax Treaty. The earlier OECD proposals, which set out alternative approaches to a number of significant PE issues, have been replaced by a set of definitive proposals which are largely focused on expanding the scope of the dependent agent rule (including narrowing the scope of the independent agent rule) and narrowing the scope of the specific activity PE exemptions.
An important element of the package is a proposed anti-fragmentation rule intended to prevent abuse of the PE rules by segregating activities across associated entities. Taken together, the proposed rules will clearly expand the scope of existing PE rules.

OECD releases revised base erosion and profit shifting proposals on permanent establishments
May 2015

International tax news: May 2015
This monthly newsletter from PwC's International Tax Network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International tax news: May 2015
May 2015

Base erosion and profit shifting (BEPS) proposals address intangibles cost contribution arrangements
Multinational enterprises involved in the development and use of intangibles under cost contribution arrangements (CCAs) should note the 29 April 2015 discussion draft proposals under Action 8 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The discussion draft proposes fundamental modifications to Chapter VIII of the OECD Transfer Pricing Guidelines.

Tax Policy Bulletin: May 2015
May 2015

International tax news: April 2015
This monthly newsletter from PwC's International Tax Network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International tax news: April 2015
April 2015

European investor tax reporting
Investor tax reporting is a complex and constantly evolving area. In recent years several jurisdictions including Austria, Germany, Switzerland and the UK have introduced new tax reporting regimes or modified existing ones. In order to compete and effectively market their products across Europe fund managers now require a deeper understanding of country specific investor tax reporting requirements. The dedicated asset management tax team in PwC Ireland presents a comprehensive multi-jurisdictional tax reporting solution for investment funds.

The Irish Funds Industry: Strong growth in 2014
March 2015

Investing in Ireland: Issue 22
The strong pipeline of new Irish investments by first time and existing investors continues in 2015, with Dublin being recognised as one of the world's most vibrant cities.

On the legislative front, the entry into law in June 2015 of Ireland's Companies Act 2014, as well as planning for the "Knowledge Development Box" to be introduced in 2016, will be of interest to new and existing investors alike.

For companies in the online/B2C sector, the new 2015 VAT rules should mean that Ireland is an even more attractive location for such businesses to locate centralised EU hubs which can manage all EU VAT obligations.

Investing in Ireland: Issue 22
March 2015

PwC India Indirect Tax & Customs Newsletter: February 2015
This newsletter provides important judicial and legislative developments relating to Service Tax, Central Excise, VAT/CST, Customs, Foreign Trade Policy & WTO provisions in India.

PwC India Indirect Tax & Customs Newsletter: February 2015
February 2015

European cities hotel forecast for 2015 and 2016: Room for growth
The survey benchmarks occupancy and average daily room rates and growth for 20 gateway European cities including Dublin for 2015 and 2016. It finds that Dublin has the highest revenue per room for 2015 and 2016.

European cities hotel forecast for 2015 and 2016
March 2015

Tax facts 2015
This publication is a practical and easy-tofollow guide to the Irish tax system. It provides a summary of Irish tax rates as well as an outline of the main areas of Irish taxation.

Tax facts 2015
February 2015

U.K patent box claims
As part of the Government's aim to encourage innovation in the UK and increase tax competitiveness, a 10% tax rate now applies to profits falling within the Patent Box. This provides a significant tax saving compared to the main rate of corporation tax in the UK.

U.K patent box claims
February 2015

Multinationals receive OECD country-by-country reporting, multilateral instrument and IP tax incentive BEPS proposals
Multinational enterprises (MNEs) recently received additional guidance on complying with certain recommendations emanating from the OECD's base erosion and profits shifting (BEPS) Action Plan. MNEs will be particularly interested in the roll-out of country-by-country tax information reporting to tax authorities. They will also be interested in the criteria countries should require in order for them to benefit from intellectual property (IP) tax incentive regimes.

Multinationals receive OECD country-by-country reporting
February 2015

Italy’s new Patent Box regime additional flexibility
Italy has introduced a Patent Box regime based on the “nexus approach” set out by the Organisation for Economic Co-operation and Development (OECD). Only a month after the Italian Parliament approved the 2015 Finance Act (Law no 190 of December 23, 2014), which enacted the Italian Patent Box regime, the Italian Government has extended its scope through a Law Decree “Investment Compact”, which is due to be converted into law within 60 days of its publication in the Official Gazette on January 24, 2015.

Italy’s new Patent Box regime additional flexibility
February 2015

Customs & International Trade Communiqué edition 67
In this edition you will find articles regarding ECJ case law, changes in EU legislation, some country specific updates including recent excise changes in Ireland and the usual updates on tariff classification and anti-dumping.

Customs & International Trade Communiqué edition 67
February 2015

PwC India Indirect Tax & Customs Newsletter: January 2015
This newsletter provides important judicial and legislative developments relating to Service Tax, Central Excise, VAT/CST, Customs, Foreign Trade Policy & WTO provisions in India

PwC India Indirect Tax & Customs Newsletter: January 2015
February 2015

International tax news: February 2015
This monthly newsletter from PwC's International Tax Network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International Tax News: February 2015
February 2015

RCT obligations for the Telecommunications Sector
Overview of RCT considerations for those operating in the Telecommunications Sector

RCT obligations for the Telecommunications Sector
January 2015

International tax news: December 2014/January 2015
This monthly newsletter from PwC's International Tax Network provides an overview of international tax developments from countries worldwide. In this edition, new tax legislation and tax treaties are announced for a number of countries around the globe.

International Tax News: December 2014/January 2015
January 2015

Knowledge development box: Consultation process
On October 14, 2014, the Minister for Finance delivered the Irish Budget for 2015 in which he announced plans to introduce a new ‘Knowledge Development Box’ (KDB).

The Department of Finance launched a public consultation on the KDB regime on January 14, 2015. They have requested submissions to be made on the design of the KDB with the goal of ensuring “it meets its key objective of being the most competitive in class within the agreed international parameters for fair tax competition in this area”. The consultation process runs until April 8, 2015.

Knowledge development box: Consultation process
January 2015

UK to introduce legislation to implement country-by-country reporting
Following the UK's lead as the first country to commit publicly to adopting the country-by-country reporting (CBCR) template developed by the Organisation for Economic Co-operation and Development (OECD), the Government has now published the draft legislation to enable the introduction of CBCR in the UK.

The legislation, which will be included in the Finance Act 2015, confirms that UK parented multinational enterprises (MNEs) will be required to provide CBCR tax related data to HM Revenue & Customs (HMRC) as part of this requirement.

The draft legislation and its accompanying explanatory notes also indicates how the implementing regulation is to be introduced as well as the impact it is expected to have on business. The draft legislation at this point does not specify a proposed date for implementation, but the expectation is that MNEs will be required to prepare the CBCR template for financial years beginning on or after 1 January 2016.

UK to introduce legislation to implement country-by-country reporting
January 2015

Australia: Transfer pricing documentation simplification measures
The Australian Taxation Office (ATO) has published its online guidance in relation to 'Simplifying transfer pricing record keeping'. If a taxpayer elects to apply a simplified record keeping option outlined in this guidance, Practice Statement Law Administration (PS LA) 2014/3 explains that the Commissioner will not review the taxpayer's records beyond confirming its eligibility. This guidance provides effective safe harbours for small taxpayers, small-to-medium sized distributors, low-risk intragroup services and low-level intragroup loans.

Australia: Transfer pricing documentation simplification measures
January 2015

Emerging trends in real estate 2015
Emerging Trends in Real Estate Europe, a trends and forecast publication now in its 12th edition, is a highly regarded and widely read report in the real estate industry. Undertaken jointly by PwC and Urban Land Institute, the report provides an outlook on real estate investment and development trends, real estate finance and capital markets, cities, property sectors and other real estate issues throughout Europe.

Emerging Trends in Real Estate Europe 2015 reflects the views of nearly 500 individuals who completed surveys or were interviewed as a part of the research for this report. The views expressed, including all comments appearing in quotes, are from these surveys and interviews and do not express the opinions of either PwC or ULI. The interviewees and survey participants represent a wide range of industry experts, including investors, fund managers, developers, property companies, lenders, brokers, advisers and consultants.

Emerging trends in real estate 2015
January 2015

Discussion drafts released in six BEPS-related areas raise more concerns for MNEs
Multinational enterprises (MNEs) may be concerned about various aspects of the six Discussion Drafts released last week as part of the Base Erosion and Profit Shifting (BEPS) Action Plan.

Three of the papers are within Action items 8 to 10 of the BEPS Action Plan dealing with assuring that transfer pricing outcomes are in line with value creation. One of the other papers is the first step towards producing best practice rules to address base erosion and profit shifting through the use of interest expense within Action item 4 of the Plan. The latest proposed additions to the draft International VAT/GST Guidelines relate to supplies of services and intangibles to consumers, raised in the initial report on the digital economy within Action 1. The final paper is an overarching look at the resolution process involving cross-border tax disputes.

Responding directly to the OECD with specific examples is the most powerful way that businesses can address issues which would arise if proposals were adopted. Businesses may also like to consider attending and speaking at the various public consultation meetings on these papers at the OECD's offices in Paris.

Discussion drafts released in six BEPS-related areas raise more concerns for MNEs
January 2015

Australia: Final ATO guidance on transfer pricing documentation and penalties
The Australian Taxation Office (ATO) has finalised its guidance on transfer pricing documentation and penalties under the new transfer pricing regime. The final guidance was issued in Taxation Ruling 2014/8 on transfer pricing documentation, and two practice statements: PS LA 2014/2 on penalties under the new transfer pricing regime and PS LA 2014/3 on simplifying transfer pricing record keeping.

The ‘simplification’ guidance will provide exemptions from preparing transfer pricing documentation for certain categories of taxpayers and transactions. The details and eligibility criteria will be published in an online guide which is expected to be available within the next week. PwC will issue a further update when the guide is published.

Australia: Final ATO guidance on transfer pricing documentation and penalties
January 2015

UK Diverted Profits Tax to be introduced
HM Revenue & Customs (HMRC) released the diverted profits tax (DPT) provisions within its draft Finance Bill 2015. From our initial review of the legislation, many more companies than might have been anticipated could be effected by these new rules.

The DPT is a new tax, charged at 25% on profits that are considered to be artificially diverted from the UK. The legislation is very complex; there are two sets of conditions where DPT would be applicable, and often both will apply to the same fact pattern.

In summary, the DPT might apply to:
  • a company which has UK sales being made by a related non UK company or Permanent Establishment (PE); and/or
  • a UK company/PE which has a significant transaction with a related company and, in either case, any related income ends up in a related company with a low tax rate/concessionary tax treatment.

UK Diverted Profits Tax to be introduced
January 2015

PwC India Indirect Tax & Customs newsletter: December 2014
This newsletter provides important judicial and legislative developments relating to service tax, central excise, VAT/CST, customs, foreign trade policy & WTO provisions in India

PwC India indirect tax & customs newsletter: December 2014
January 2015

IPOWatch Europe Q3 2014
Overvivew of European IPO Market.

IPOWatch Europe Q3 2014
January 2015