Tax & Transfer Pricing — 118 Nodes
- 2010 Report on the Attribution of Profits to Permanent Establishments
This report establishes the Authorised OECD Approach (AOA) for attributing profits to a permanent establishment (PE) for corporate income tax purposes, as endorsed by the OECD Council. The AOA requires treating the PE… - 26 U.S. Code § 482 - Allocation of income and deductions among taxpayers
This regulation authorizes the Secretary of the Treasury to allocate income, deductions, credits, or allowances between related organizations or businesses to prevent tax evasion or clearly reflect income. It… - 26 USC § 482 - Allocation of Income and Deductions (US Transfer Pricing Authority)
26 USC § 482 (originally enacted as § 45 of the Revenue Act of 1928, recodified into Internal Revenue Code; substantially modified by Tax Reform Act of 1986 with the addition of the commensurate-with-income standard)… - 26 USC § 6038A - Information Reporting for 25-Percent Foreign-Owned Corporations
26 USC § 6038A (enacted by Pub. L. 101-239 and substantially expanded by subsequent statutes including the Tax Cuts and Jobs Act of 2017 amendments related to BEAT) requires domestic corporations that are 25-percent… - Allocation of Income and Deductions Among Taxpayers (Section 482) - Transfer Pricing Methods
U.S. Treasury Regulations under Section 482 empower the IRS to reallocate income, deductions, and credits between two or more commonly controlled entities to prevent tax evasion and clearly reflect income. As mandated… - An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018
The US Tax Cuts and Jobs Act 2017 requires US shareholders of controlled foreign corporations (CFCs) to include in gross income their GILTI, as defined in Section 951A. This applies to US persons who own, directly or… - AU GST Act 1999 - A New Tax System (Goods and Services Tax) Compliance for Digital Services and Imported Low-Value Goods
Australia's GST Act 1999 applies 10% GST to digital services supplied by non-resident suppliers to Australian consumers with annual turnover above AUD 75,000, with offshore suppliers registering under a simplified… - Australia Income Tax Assessment Act 1997 - Assessable Income Deductions and Tax Liability
The Income Tax Assessment Act 1997 sets out the core operative rules for Australian income tax including the assessability of ordinary income and statutory income, general and specific deductions, capital allowances and… - Australia Transfer Pricing Laws Amendment Act 2012
The Australia Transfer Pricing Laws Amendment Act 2012 requires that Australian taxpayers ensure their cross-border transactions with related parties are conducted at arm's length, as per Section 815-130 of the Income… - Australian Diverted Profits Tax 2017 - 40% Tax on Artificially Diverted Australian Profits
Australian entities with global turnover above AUD 1 billion that enter into schemes to divert profits from Australia may face a 40% Diverted Profits Tax on the diverted amount. The ATO issues a DPT assessment and the… - Canada Income Tax Act Transfer Pricing Section 247
Section 247 of the Income Tax Act (R.S.C. 1985, c. 1 (5th Supp.)), as amended by the Budget Implementation Act 2023, requires that transactions and arrangements between a Canadian taxpayer and a non-arm's length… - Common Reporting Standard on Automatic Exchange of Financial Account Information for Tax Purposes (CRS), 2014 Edition
The OECD Common Reporting Standard (CRS) requires financial institutions in participating jurisdictions to identify financial accounts held by tax residents of foreign jurisdictions and report account information… - Corporate Alternative Minimum Tax (CAMT) under the Inflation Reduction Act of 2022 (IRC § 55)
The Corporate Alternative Minimum Tax (CAMT) imposes a 15% minimum tax on the adjusted financial statement income (AFSI) of applicable corporations with average annual AFSI exceeding $1 billion, as established by… - Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market
This directive establishes binding anti-abuse rules for all EU Member States, including an interest limitation rule (Article 4), controlled foreign company (CFC) rules (Article 7), a general anti-abuse rule (GAAR)… - Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (ATAD 1)
This directive requires EU Member States to implement anti-abuse rules including a 30% EBITDA-based interest limitation rule (Article 4), controlled foreign company (CFC) rules (Article 7), general anti-abuse rule… - Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (ATAD)
This directive establishes minimum standards for EU Member States to counter corporate tax avoidance by implementing five legally binding anti-abuse measures: an interest limitation rule (Article 4), exit taxation rules… - Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164 as regards hybrid mismatches with third countries
ATAD2 introduces rules to neutralize tax advantages arising from hybrid mismatch arrangements involving third countries, including imported hybrid mismatches and reverse hybrids. It applies to multinational enterprises… - Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164 as regards hybrid mismatches with third countries
This directive amends the EU's Anti-Tax Avoidance Directive (ATAD) to neutralize tax mismatches arising from hybrid arrangements involving third countries. It requires EU Member States to deny a deduction for a payment… - Council Directive (EU) 2018/822 (DAC6) - Mandatory Disclosure of Cross-Border Tax Arrangements: Hallmarks A-E, Intermediary and Taxpayer Reporting, 30-Day Reporting Deadline, Automatic Exchange Between EU Member States and 50% EBIT Threshold for Hallmark E Transfer Pricing Arrangements
Council Directive (EU) 2018/822 of 25 May 2018 (DAC6) amends Directive 2011/16/EU to require mandatory disclosure to national tax authorities of potentially aggressive cross-border tax arrangements; primary reporting… - Council Directive (EU) 2018/822 (DAC6) - Mandatory Disclosure of Reportable Cross-Border Tax Arrangements: Hallmark Categories A-E, 30-Day Reporting Window, Intermediary and Taxpayer Obligations, Main Benefit Test and Automatic Competent Authority Exchange
Intermediaries (advisers, banks, accountants) who design, market, organise, or implement cross-border arrangements with at least one hallmark indicating potential tax avoidance must report to their Member State… - Council Directive (EU) 2018/822 (DAC6) on mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements
This directive, known as DAC6, requires EU intermediaries (e.g., tax advisors, lawyers, banks) or, in some cases, the relevant taxpayer, to report potentially aggressive cross-border tax planning arrangements to their… - Council Directive (EU) 2018/822 of 25 May 2018 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements
This Directive requires intermediaries and, in certain cases, taxpayers to report cross-border arrangements that meet one or more of the hallmarks listed in Article 4 within 30 days of the arrangement being made… - Council Directive (EU) 2020/262 of 19 December 2019 laying down the general arrangements for excise duty (recast)
This Directive lays down the general arrangements for excise duty levied on the consumption of energy products, alcohol and tobacco (Article 1). It defines the taxable event as the production or importation of excise… - Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable digital platform transactions
Digital platform operators must report annual information on sellers engaged in immovable property rentals, personal services, sale of goods, and vehicle rentals to tax authorities under Article 10a of DAC7. This data… - Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation in relation to reportable digital platform transactions
DAC7 requires digital platform operators to conduct due diligence on sellers providing accommodation, personal services, goods, or vehicle rentals via their platforms, report seller income annually to tax authorities,… - Council Directive (EU) 2021/514 of 22 March 2021 amending Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC7)
EU Directive 2021/514 (DAC7) requires digital platform operators to collect, verify, and report information on income earned by sellers for relevant activities to EU Member State tax authorities. This obligation,… - Council Directive (EU) 2022/2523 - Global Minimum Level of Taxation for MNE Groups: 15% GloBE Rules, Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), Qualified Domestic Minimum Top-up Tax (QDMTT) and Substance-Based Income Exclusions
MNE groups with consolidated annual revenue ≥€750M must maintain ≥15% effective tax rate per jurisdiction; parent entities apply IIR to pay top-up tax on low-taxed constituent entities; UTPR backstop collects… - Council Directive (EU) 2022/2523 / OECD GloBE Model Rules - Pillar Two Global Minimum Tax: 15% Effective Tax Rate, Income Inclusion Rule, Undertaxed Profits Rule, Qualified Domestic Minimum Top-up Tax, Substance-Based Income Exclusion and GloBE Information Return
Council Directive (EU) 2022/2523 implements the OECD GloBE Model Rules in the EU, requiring multinational enterprise (MNE) groups with consolidated annual revenue of at least €750 million in at least 2 of the 4… - Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union
This directive requires EU Member States to implement the OECD's Pillar Two rules, ensuring that multinational enterprise (MNE) and large-scale domestic groups with annual consolidated revenues of €750 million or more… - Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union
This Directive establishes a global minimum tax regime requiring multinational enterprise (MNE) groups and large-scale domestic groups with consolidated revenue of at least EUR 750 000 000 to pay a minimum effective tax… - Council Directive (EU) 2023/2226 of 17 October 2023 amending Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC8)
Directive (EU) 2023/2226 (DAC8) mandates that Crypto-Asset Service Providers (CASPs) and Crypto-Asset Operators in the EU must perform due diligence on their users and report transactional data concerning crypto-assets,… - Council Directive (EU) 2025/50 of 10 December 2024 on faster and safer relief of excess withholding taxes (FASTER)
FASTER establishes a common EU digital tax residence certificate (eTRC) issued within 14 calendar days, two fast-track procedures for relieving excess withholding tax on cross-border dividend and interest income (relief… - Council Directive 2003/49/EC of 3 June 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States
This directive eliminates withholding taxes on cross-border interest and royalty payments between associated companies within the EU, provided the recipient is the beneficial owner of the income as stipulated in Article… - Council Directive 2003/49/EC of 3 June 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States
This Directive eliminates withholding taxes on interest and royalty payments between associated companies in different EU Member States, provided the beneficial owner is a qualifying associated company and the… - Council Directive 2011/96/EU of 16 November 2011 on the common system of taxation applicable to parent companies and subsidiaries of different Member States
This Directive eliminates withholding taxes on dividends paid between qualifying parent companies and subsidiaries within the EU, provided the parent holds at least 10% of the subsidiary’s capital for an uninterrupted… - Council Directive 2011/96/EU of 16 November 2011 on the common system of taxation applicable to parent companies and subsidiaries of different Member States, as amended by Council Directive 2014/86/EU to prevent double non-taxation arising from hybrid mismatch arrangements
This directive ensures that qualifying dividend distributions between EU parent and subsidiary companies are exempt from withholding tax, provided certain conditions are met, including anti-abuse rules introduced by… - Council Directive 2014/107/EU of 9 December 2014 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation
This Directive mandates EU Member States to automatically exchange information on financial accounts held by tax residents of other Member States, based on the OECD Common Reporting Standard (CRS). It requires Financial… - Deduction for Foreign-Derived Intangible Income and Global Intangible Low-Taxed Income (26 U.S.C. § 250)
This regulation, under 26 U.S.C. § 250, allows eligible U.S. C corporations to claim a deduction on their Foreign-Derived Intangible Income (FDII) and Global Intangible Low-Taxed Income (GILTI). The FDII deduction… - Directive (EU) 2016/1065 - VAT Treatment of Single-Purpose and Multi-Purpose Vouchers
Directive (EU) 2016/1065 amends the VAT Directive 2006/112/EC to harmonise the VAT treatment of vouchers by inserting Articles 30a, 30b and 73a. A voucher is an instrument carrying an obligation to accept it as… - Directive (EU) 2021/2101 of the European Parliament and of the Council of 24 November 2021 amending Directive 2013/34/EU as regards disclosure of income tax information by certain undertakings and branches
This directive requires multinational enterprises (MNEs) and standalone undertakings with total consolidated revenue exceeding €750 million for two consecutive financial years to publicly disclose corporate income tax… - Directive 2009/55/EC - Tax Exemptions on the Permanent Introduction of Personal Property from Another Member State
Directive 2009/55/EC requires every Member State to exempt personal property permanently introduced from another Member State by a private individual from the consumption taxes that normally apply to such property. The… - EU Anti-Tax Avoidance Directives - ATAD1 (Council Directive (EU) 2016/1164) and ATAD2 (Council Directive (EU) 2017/952)
The EU Anti-Tax Avoidance Directive 1 (ATAD1), adopted by the Council of the European Union on 12 July 2016 as Council Directive (EU) 2016/1164, establishes a minimum standard of anti-avoidance measures across all EU… - EU DAC6 Mandatory Disclosure Regulation 2018/822 - Hallmarks, Intermediary Obligations, and Cross-Border Reporting
EU Council Directive 2018/822 (DAC6) requires intermediaries (primarily tax advisors, accountants, lawyers, and financial institutions) to report cross-border tax arrangements that meet one or more of the defined… - EU Mandatory Disclosure Rules - DAC6 Directive 2018/822/EU
EU Directive 2018/822/EU (DAC6) requires intermediaries and taxpayers to report cross-border tax arrangements bearing specified hallmarks to national tax authorities within 30 days; information is automatically… - EU Tax Dispute Resolution Directive 2017/1852 - Double Taxation Dispute Mechanism
Council Directive (EU) 2017/1852 on tax dispute resolution mechanisms in the European Union requires Member States to resolve double taxation disputes between EU Member States within 2 years of a complaint being… - EU VAT Directive 2006/112 - Standard Rate, Deduction, Intra-EU Supply, and One-Stop-Shop
Council Directive 2006/112/EC on the common system of value added tax (the Principal VAT Directive) consolidates previous EU VAT directives and establishes the common framework for VAT across all EU Member States.… - EU VAT Directive 2006/112/EC - Cross-Border Digital Services and One-Stop Shop (OSS) Registration
EU VAT Directive 2006/112/EC as amended by Directive 2017/2455 requires suppliers of digital services to EU consumers to charge VAT at the consumer's member state rate, with the One-Stop Shop (OSS) scheme allowing… - Fiscal Code of Germany (Abgabenordnung - AO)
This Code is the general tax code of Germany, governing the procedural framework common to all taxes (Section 1), subject to the primacy of international agreements (Section 2). It defines taxes as payments of money,… - Foreign Account Tax Compliance Act (FATCA)
FATCA requires foreign financial institutions (FFIs) and certain non-financial foreign entities to report on U.S. account holders' foreign assets or face 30% withholding on withholdable payments. It also mandates U.S.… - Foreign Account Tax Compliance Act (FATCA)
The Foreign Account Tax Compliance Act (FATCA) requires foreign financial institutions (FFIs) and certain non-financial foreign entities to report information on financial accounts held by U.S. persons, or be subject to… - GST Appellate Tribunal (GSTAT) - Section 109 of the Central Goods and Services Tax Act, 2017, as amended by the Finance Act 2023
The GST Appellate Tribunal (GSTAT) is established under Section 109 of the Central Goods and Services Tax Act, 2017 (CGST Act), as amended by the Finance Act 2023, for resolving disputes under the Goods and Services Tax… - Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles (BEPS Action 8)
This guidance permits tax administrations to use ex-post outcomes (actual financial results) as presumptive evidence to challenge the arm's length pricing of Hard-to-Value Intangibles (HTVI) transfers between related… - Guidance Related to the High-Tax Exception Under Subpart F and the High-Tax Exclusion for Global Intangible Low-Taxed Income
These final regulations permit U.S. shareholders of controlled foreign corporations (CFCs) to elect to exclude items of high-taxed income from their Global Intangible Low-Taxed Income (GILTI) computation on a… - Gulf Cooperation Council VAT Unified Agreement 2016
This regulation establishes a unified value-added tax framework across GCC member states, mandating a standard 5% VAT rate, zero-rating for international services, and exemptions for healthcare and education services.… - HMRC International Transfer Pricing Guidelines (INTM) - UK Arm's Length Principle Application: Thin Cap Rules (Replaced by Interest Limitation), Advance Thin Cap Agreements, Mutual Agreement and MAP Process
The UK transfer pricing rules, as reformed effective 1 January 2026, require that transactions between connected parties be conducted at arm’s length, with specific rules on interest deductibility and thin… - Income Tax Act (R.S.C., 1985, c. 1 (5th Supp.)) - Section 247
This article defines key terms related to transfer pricing, including arm's length principles, qualifying cost contribution arrangements, and various types of tax adjustments, which form the basis for determining tax… - Income Tax Act, Section 247 - Arm's Length Transactions, Recharacterisation Power, Contemporaneous Documentation and Penalties
This regulation requires Canadian taxpayers to ensure arm's length transactions with non-resident related parties, as per Section 247 of the Income Tax Act, and maintain contemporaneous documentation to support transfer… - India Income-tax Rules 10F-10T: Advance Pricing Agreement Scheme
India's Advance Pricing Agreement (APA) scheme is set out in Rules 10F to 10T of the Income-tax Rules, 1962, inserted by the Income-tax (Tenth Amendment) Rules, 2012 (effective 30 August 2012) and made under sections… - India Transfer Pricing - Section 92 of the Income Tax Act 1961 (Arm's Length Standard)
Sections 92 to 92F of the Income Tax Act 1961 (as inserted by the Finance Act 2001 and substantially amended since) establish India's transfer pricing framework for international transactions and specified domestic… - Internal Revenue Code Section 59A: Tax on Base Erosion Payments of Taxpayers With Substantial Gross Receipts
The Base Erosion and Anti-Abuse Tax (BEAT) under IRC Section 59A imposes a minimum tax on large corporations ($500M+ average annual gross receipts) that reduce their U.S. tax liability by making certain 'base erosion… - Loi 2019-759 du 24 juillet 2019 portant création d'une taxe sur les services numériques
This regulation requires large tech companies to pay a 3% tax on their French digital revenue, as stated in Article 1 of the law. It applies to companies with global revenues exceeding €750 million and French revenues… - Loi de Finances pour 2024 (Loi n° 2023-1322, art. 33) - Transposition en droit français du régime GloBE (Pilier Deux de l'OCDE) : impôt complémentaire codifié aux articles 223 VJ à 223 WZ du CGI, IIR, QDMTT et déclaration d'information GloBE auprès de la DGFiP
Article 33 of Loi n° 2023-1322 du 29 décembre 2023 de finances pour 2024 transposes EU Directive (UE) 2022/2523 (the OECD Pillar Two GloBE rules) into French law, effective for fiscal years opened on or after 31… - Methods to Determine Taxable Income in Connection with a Cost Sharing Arrangement
This regulation requires controlled participants in a Qualified Cost Sharing Arrangement (CSA) to share intangible development costs (IDCs) in proportion to their reasonably anticipated benefits (RAB) and to make arm's… - Multilateral Convention to Implement Amount A of Pillar One - Reallocation of Taxing Rights for MNEs above €20bn Revenue and 10% Profitability Threshold
This multilateral convention reallocates taxing rights on a portion of residual profits from the largest and most profitable Multinational Enterprises (MNEs) to the market jurisdictions where their customers are… - Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI)
The OECD BEPS Action 15 Multilateral Instrument (MLI) enables over 100 jurisdictions to swiftly implement BEPS minimum standards into their bilateral tax treaties, including treaty override mechanisms, a Principal… - Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) - Article 7: Prevention of Treaty Abuse
The OECD's Multilateral Instrument (MLI) Article 7 implements BEPS Action 6, requiring signatory jurisdictions to adopt a Principal Purpose Test (PPT) to deny tax treaty benefits where obtaining such benefits was a… - New Zealand Goods and Services Tax Act 1985 - GST Rate, Registration, Zero-Rating, and Exempt Supplies
The Goods and Services Tax Act 1985 (New Zealand) (GST Act) imposes a goods and services tax on the supply of goods and services in New Zealand and on goods imported into New Zealand. Section 6 imposes GST on taxable… - OECD Base Erosion and Profit Shifting (BEPS) Action 13 - Transfer Pricing Documentation and Country-by-Country Reporting
Requires multinational enterprise (MNE) groups with consolidated group revenue of EUR 750 million or more to prepare a three-tiered transfer pricing documentation structure: Master File, Local File, and… - OECD BEPS Action 12 - Mandatory Disclosure Rules (MDR)
OECD BEPS Action 12 Final Report (2015) and the 2023 Reporting Framework for Digital Platform Operators provide recommended rules requiring promoters and users of aggressive tax arrangements to disclose them to tax… - OECD BEPS Action 13 Country-by-Country Reporting Guidance 2023 - Domestic Filing Obligations, Exchange Framework and Confidentiality Safeguards
This regulation requires multinational enterprises (MNEs) to file a country-by-country report (CbCR) with their tax authority, as outlined in Article 3 of the OECD Model Legislation, and applies to MNEs with a… - OECD BEPS Action 13: Transfer Pricing Documentation and Country-by-Country Reporting - Master File, Local File, and CbC Report Requirements
Multinational enterprises (MNEs) with annual consolidated revenue of EUR 750 million or more must prepare a Master File, Local File, and Country-by-Country Report (CbCR) to demonstrate compliance with the arm’s length… - OECD BEPS Action 6 - Prevention of Treaty Abuse 2015: Principal Purpose Test (PPT), Limitation on Benefits (LOB) Clause, Minimum Standard for Inclusion in Tax Treaties, Entitlement to Treaty Benefits Analysis, Derivative Benefits Provision and Holding Structures
This regulation establishes a minimum standard to prevent treaty shopping by requiring tax treaties to include a Principal Purpose Test (PPT) or Limitation on Benefits (LOB) clause. It applies to all multinational… - OECD BEPS Actions 8-10 - Transfer Pricing and Value Creation
OECD BEPS Actions 8-10 Final Reports (2015), incorporated into the OECD Transfer Pricing Guidelines (2022 edition), mandate that profits follow value creation by aligning transfer pricing outcomes with the actual… - OECD Crypto-Asset Reporting Framework (CARF) 2022 - Tax Reporting Obligations for Crypto-Asset Service Providers and Automatic Exchange with Tax Authorities
The OECD's Crypto-Asset Reporting Framework (CARF) mandates that Crypto-Asset Service Providers (CASPs) conduct due diligence on their customers and report detailed information on crypto-asset transactions annually to… - OECD Global Forum on Transparency and Exchange of Information for Tax Purposes: Phase 2 Peer Reviews
The OECD Global Forum Phase 2 Peer Reviews require jurisdictions to have in place a legal framework that enables the exchange of information on request (EOIR) in accordance with Article 26 of the OECD Model Tax… - OECD Inclusive Framework on BEPS - 140+ Countries: Four Minimum Standards (Actions 5, 6, 13, 14), Peer Reviews, Capacity Building, Pillar One and Pillar Two Implementation and IF Deliverables
The OECD Inclusive Framework on Base Erosion and Profit Shifting (BEPS) requires 140+ jurisdictions to implement four minimum standards: countering harmful tax practices (Action 5), preventing treaty abuse (Action 6),… - OECD Model Tax Convention Article 9 - Associated Enterprises and Arm's Length Principle: Conditions for Adjustment, Primary Adjustment, Corresponding Adjustment, Mutual Agreement Procedure and Secondary Adjustments
This regulation requires that transactions between associated enterprises be priced as if they were conducted between independent parties (arm’s length principle) under Article 9(1) of the OECD Model Tax Convention. It… - OECD Model Tax Convention on Income and on Capital: Condensed Version 2017
The OECD Model Tax Convention 2017 provides the global standard framework for bilateral tax treaties to eliminate double taxation and prevent fiscal evasion. It establishes rules for residence tie-breaker (Article 4),… - OECD Pillar One - Amount A: Reallocation of Residual Profits to Market Jurisdictions Based on Revenue Threshold, Profitability, and Nexus Rules
This regulation requires multinational enterprises (MNEs) with global revenue above USD 20 billion and profitability exceeding 10% to reallocate 25% of residual profits to market jurisdictions where revenue is… - OECD Pillar One Amount A - Reallocation of Profits to Market Jurisdictions for Large Multinational Enterprises
Requires multinational enterprises (MNEs) with global revenue over €20 billion and profitability exceeding 10% to reallocate 25% of residual profits to market jurisdictions where revenue is sourced, based on nexus… - OECD Pillar Two - Global Anti-Base Erosion (GloBE) Rules 15% Global Minimum Tax
OECD Pillar Two GloBE Rules impose a global minimum effective tax rate of 15% on multinational enterprises with annual consolidated revenue exceeding EUR 750 million - implemented via Income Inclusion Rule (IIR) and… - OECD Pillar Two - Global Anti-Base Erosion (GloBE) Rules: Income Inclusion Rule, Undertaxed Profits Rule, 15% Global Minimum Tax, Substance-Based Income Exclusion, QDMTT and Safe Harbour Provisions
This regulation establishes a global minimum corporate tax rate of 15% for multinational enterprise (MNE) groups with revenue above EUR 750 million, applying the Income Inclusion Rule (IIR) and Undertaxed Profits Rule… - OECD Pillar Two - Global Minimum Tax 15% GloBE Rules and Qualified Domestic Minimum Top-up Tax
OECD Pillar Two GloBE Rules require large multinational enterprises with consolidated revenue above EUR 750 million to pay a minimum effective tax rate of 15% in each jurisdiction, with top-up tax collected by the… - OECD Pillar Two - Qualified Domestic Minimum Top-Up Tax (QDMTT) and Undertaxed Profits Rule (UTPR)
OECD Pillar Two GloBE Rules establish a 15% global minimum effective tax rate for MNE groups with consolidated revenue of EUR 750 million or more. The Qualified Domestic Minimum Top-Up Tax (QDMTT) allows jurisdictions… - OECD Transfer Pricing Guidance on Financial Transactions 2020 - Accurate Delineation, Treasury Functions, Cash Pooling and Financial Guarantees
This guidance requires multinational enterprises (MNEs) to accurately delineate and price intra-group financial transactions, including loans, cash pooling, hedging, and financial guarantees, in accordance with the… - OECD Transfer Pricing Guidelines - Chapter I: The Arm's Length Principle and Comparability Analysis
OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2022 edition) Chapter I establishes the arm's length principle (ALP) as the international standard for pricing controlled… - OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2022 Edition)
This regulation establishes the international standard for applying the arm’s length principle to transfer pricing between related parties in multinational enterprises. It requires taxpayers and tax administrations to… - OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022
These guidelines provide the international consensus on valuing cross-border transactions between associated enterprises within a Multinational Enterprise (MNE) group for tax purposes. They mandate the application of… - OECD WCO Customs Valuation and Transfer Pricing Interface - Resolving Conflicts Between Customs Value and Arm's Length Price for Related Parties
This regulation requires customs authorities and tax administrations to resolve conflicts between customs value and arm's length price for related parties, as outlined in Article 1 of the OECD WCO Customs Valuation and… - OECD/COE Convention on Mutual Administrative Assistance in Tax Matters 1988/2010 - AEOI and Tax Information Exchange
The Multilateral Convention on Mutual Administrative Assistance in Tax Matters (1988, amended by 2010 Protocol - 147 jurisdictions as of 2025) is the overarching legal basis for the OECD/G20 global tax transparency… - Plastic Packaging Tax: steps to take - HM Revenue & Customs Guidance
Businesses that have manufactured or imported 10 or more tonnes of finished plastic packaging components in the last 12 months must register for the Plastic Packaging Tax. The tax applies at £228.82 per tonne from 1… - Proposal for a Council Directive on Business in Europe: Framework for Income Taxation (BEFIT)
The BEFIT directive proposes a common framework for EU-based multinational groups with annual combined revenues exceeding €750 million to calculate a single taxable base, replacing diverse national rules. As outlined in… - Proposal for a COUNCIL DIRECTIVE on laying down rules on a debt-equity bias reduction allowance and on limiting the deductibility of interest for corporate income tax purposes
This proposed EU directive aims to equalize the tax treatment of debt and equity financing by introducing a notional interest deduction on increases in equity (Article 4) and a new limitation on interest deductibility… - Proposal for a Council Directive on Transfer Pricing
This proposed directive requires multinational enterprises operating in the EU to ensure that the terms and conditions of their cross-border transactions between associated enterprises are consistent with the arm's… - Revenue Procedure 2015-41: Procedures for Advance Pricing Agreements
This procedure outlines the process for taxpayers to request an Advance Pricing Agreement (APA) with the IRS to prospectively resolve transfer pricing issues, detailing the mandatory prefiling, application content, and… - Singapore Goods and Services Tax Act 1993
The Goods and Services Tax Act (Cap. 117A, 2005 Rev. Ed.), as amended with the GST rate increased to 9% effective 1 January 2024 from 8% on 1 January 2023 and 7% prior to that, requires any person who makes taxable… - Singapore IRAS Transfer Pricing Guidelines 6th Edition 2021 - Documentation Requirements, Advance Pricing Agreements and MAP Procedures
This regulation requires multinational enterprises to maintain transfer pricing documentation as per Section 3.1 of the guidelines, and applies to all entities with cross-border transactions. See Section 2.1 for… - South Africa Tax Administration Laws Amendment Act 4 of 2026 - Section 223 Understatement Penalties, Suspension of Payment, and VAT E-Invoicing
Taxpayers in South Africa must comply with the amended understatement penalty rules under section 223 of the Tax Administration Act 28 of 2011, may apply for suspension of payment while requesting a reduced assessment… - Standard for Automatic Exchange of Financial Account Information in Tax Matters (Common Reporting Standard - CRS)
The OECD Common Reporting Standard (CRS) mandates that financial institutions in participating jurisdictions collect and report financial account information of non-resident customers to their local tax authorities for… - Tax Challenges Arising from the Digitalisation of the Economy - Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), July 2023
This OECD guidance provides further clarification on the application of the Pillar Two Global Anti-Base Erosion (GloBE) rules for Multinational Enterprises (MNEs) with revenues over €750 million. It details the… - Tax Challenges Arising from the Digitalisation of the Economy - Global Anti-Base Erosion Model Rules (Pillar Two)
The OECD Pillar Two GloBE Model Rules require multinational enterprises (MNEs) with annual consolidated revenues exceeding €750 million to pay a minimum effective tax rate (ETR) of 15% on profits in each jurisdiction… - The Constitution (One Hundred and First Amendment) Act, 2016, and The Central Goods and Services Tax Act, 2017, Integrated Goods and Services Tax Act, 2017, and Union Territory Goods and Services Tax Act, 2017
The India Goods and Services Tax (GST) 2017 establishes a dual GST model (CGST/SGST/IGST), mandates e-invoicing for taxpayers with aggregate turnover above ₹5 crore, requires annual return filing (GSTR-9), implements… - UK Corporation Tax Act 2010 - Diverted Profits Tax, Transfer Pricing, and Hybrid Mismatch Rules
UK Corporation Tax Act 2010 and associated legislation impose 25% Diverted Profits Tax on profits diverted from the UK, require arm's-length transfer pricing on related-party transactions, and deny deductions for hybrid… - UK Diverted Profits Tax 2015 - 31% Charge on Diverted UK Profits
UK Diverted Profits Tax (DPT) charges a 31% rate on profits artificially diverted from the UK using contrived arrangements, mainly targeting: (1) foreign companies avoiding a UK permanent establishment through… - UK Finance Act 2024 - R&D Tax Relief Reform, Multinational Top-Up Tax (Pillar Two), and Pension Allowances Removal, Royal Assent 22 February 2024
UK taxpayers, multinational groups, R&D-intensive companies, and pension scheme administrators must comply with the Finance Act 2024 (Royal Assent 22 February 2024) by applying the new merged R&D tax relief scheme under… - UK Transfer Pricing - Taxation (International and Other Provisions) Act 2010 and OECD BEPS Action 13 Documentation
The UK transfer pricing rules, codified in Pt. 4 and Pt. 5 of the Taxation (International and Other Provisions) Act 2010 (TIOPA 2010), require that transactions between associated enterprises be conducted on arm's… - United States Tax Court (Title 26 USC Chapter 76 Subchapter C): Article I Court of Record Status, Jurisdiction, Nineteen-Member Composition, Special Trial Judges, Sessions, and Appellate Review
The United States Tax Court, established by Subchapter C of Chapter 76 of Title 26 of the United States Code, is a court of record under Article I of the Constitution of the United States with jurisdiction conferred on… - US FATCA - Foreign Account Tax Compliance Act: FFI Agreement, FATCA Withholding, and GIIN Registration
US Foreign Account Tax Compliance Act (FATCA), enacted in the Hiring Incentives to Restore Employment (HIRE) Act 2010 and implemented via IRC Sections 1471-1474, requires foreign financial institutions (FFIs) to report… - US Foreign Account Tax Compliance Act (FATCA) - IRS
FATCA (IRC Chapter 4, sections 1471-1474) requires foreign financial institutions (FFIs) to identify and report US account holders to the IRS directly or via intergovernmental agreements (IGAs), withholding 30% on… - US GILTI - IRC Section 951A: Global Intangible Low-Taxed Income Inclusion and High-Tax Exclusion
US Internal Revenue Code Section 951A (GILTI), enacted by the Tax Cuts and Jobs Act 2017, requires US shareholders of Controlled Foreign Corporations (CFCs) to include in gross income their pro-rata share of GILTI… - US GILTI, BEAT, and FDII - Tax Cuts and Jobs Act 2017 International Tax Provisions
The Tax Cuts and Jobs Act (TCJA), signed into law by President Trump on 22 December 2017 (Public Law 115-97), enacted the most comprehensive reform of US international corporate taxation since 1986 and introduced three… - US Internal Revenue Code - 26 USC 6672 Failure to Collect and Pay Over Tax, or Attempt to Evade or Defeat Tax (Trust Fund Recovery Penalty)
26 USC 6672 is the Internal Revenue Code provision that imposes the Trust Fund Recovery Penalty (TFRP) personally on responsible persons who willfully fail to collect, account for, and pay over trust fund taxes.… - US Internal Revenue Code - 26 USC 7201 Attempt to Evade or Defeat Tax
26 USC 7201 titled 'Attempt to evade or defeat tax' is the principal federal criminal tax evasion statute. The statute provides that any person who willfully attempts in any manner to evade or defeat any tax imposed by… - US Internal Revenue Code - 26 USC 7206 Fraud and False Statements (Tax Perjury and Aiding Tax Fraud)
26 USC 7206 titled 'Fraud and false statements' is the federal tax-perjury and aiding-tax-fraud statute that complements 26 USC 7201 (tax evasion). Subsection (1) (the 'tax perjury' provision) makes it a felony for any… - US Internal Revenue Code - 26 USC 7434 Civil Damages for Fraudulent Filing of Information Returns
26 USC 7434 titled 'Civil damages for fraudulent filing of information returns' is the federal civil cause of action permitting any person to sue for damages when another person willfully files a fraudulent information… - US IRS Section 482 Transfer Pricing Regulations - Arm's Length Standard for Intercompany Transactions
Section 482 of the Internal Revenue Code and the accompanying Treasury Regulations (26 C.F.R. § 1.482-1 to -9) require that intercompany transactions between related parties be priced at arm's length - the price that… - US Model Income Tax Convention 2016
The US Model Income Tax Convention 2016 requires that a resident of a Contracting State be entitled to the benefits of the Convention, subject to the limitations on benefits provisions in Article 22, and that certain… - US Tax Reform Act of 1986 (Public Law 99-514) - Internal Revenue Code Recodification
The Tax Reform Act of 1986 recodified the Internal Revenue Code as Title 26 USC, broadened the individual income tax base by repealing or limiting many deductions and preferences, lowered the top individual rate from 50…
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