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Does Country-by-Country Reporting notification apply to branches?

  Yes and No. Country-by-Country Reporting (“CbCR”) notification requirements in Norway exclusively apply to tax residents, cf. Tax ...

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Country-by-Country notification in Norway

Country-by-Country Reporting is implemented in Norway with effect from FY16. Deadline for submitting the FY16 report is December 31, 2017. ...

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Norwegian IKEA debt pushdown and transfer pricing case - english translation

On October 18, 2016 the Norwegian Supreme Court made its decision in the IKEA case. The question was whether interest on inter-company ...

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Large businesses in the UK: publish your tax strategy

On 24 June 2016 HMRC published an overview guide for large businesses (with a turnover above £200 million or balance sheet over £2 ...

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IRS publish final regulations on confidential Country-by-Country Reporting

On June 30 2016, the Internal Revenue Service published a document containing final regulations that require annual country-by-country ...

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ECOFIN agrees EU-wide rules in Anti-Tax Avoidance Directive

Political agreement on the Anti-Tax Avoidance Directive (ATAD) was reached by the EU Member States in the Council of the EU, meeting ...

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OECD Council approves incorporation of BEPS amendments into the Transfer Pricing Guidelines

On 23 May 2016, the OECD Council approved the amendments to the Transfer Pricing Guidelines as set out in the 2015 BEPS Report on Actions ...

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OECD releases standardised electronic format for the exchange of BEPS Country-by-Country Reports

In a continued effort to boost transparency in international tax matters, the OECD has released its standardised electronic format for the ...

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OECD releases discussion draft on the multilateral instrument to implement the tax-treaty related BEPS measures

The OECD has published a request for input related to the development of a multilateral instrument to implement the tax-treaty related BEPS ...

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How should the Country-by-Country Reporting rules be applied to investment funds?

On June 29 2016 OECD released the report “Guidance on the Implementation of Country-by-Country Reporting: BEPS ACTION 13”. The report inter ...

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Introduction of OECD and EU Country-by-Country-reporting creates confusion

Following the publication of the final reports of the BEPS project in October 2015 OECD member countries around the globe are working on ...

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