Transfer Pricing in Tax and Legal blog
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On 7 and 8 February 2023, the Swiss Federal Tax Administration (“SFTA”) published the Swiss safe harbour interest rates applicable for the year 2023, both for intercompany (“IC”) loans and advances denominated in Swiss francs (Circular Letter No. 203) as well as in foreign currencies (Circular Letter No. 204). These rates are used by the SFTA to determine the arm’s length nature of interest on intragroup loan receivables or payables and provide a level of tax certainty from a Swiss tax perspective, in absence of a bespoke arm’s length comparability analysis.
Recent developments, such as the acceleration of the public Country-by-Country Reporting (“CbCR”) obligations by Romania, as well the newly published guidance regarding Pillar II safe harbour rules, have put increasing pressure and scrutiny on Multinational Enterprises’ (“MNEs”) CbCR obligations and will directly affect companies’ tax compliance obligations.
Join our Financial Services tax webinar on 9 November 2022 at 08:30 to discuss legislative developments, court cases and practice
We would like to invite you to our half yearly webinar where we provide key updates and discuss recent tax developments that are important for the financial services industry on Wednesday 9 November 2022 at 08:30.
The OECD has published a new, updated version of the Transfer Pricing Guidelines, which now includes the updated guidance regarding possible approaches to apply to hard-to-value intangibles, the application of the transactional profit method and new guidance on financial transactions.
New webinar date - Practical implications on the Pillar 1 & 2 policy solutions developed by the OECD
The much anticipated, updated model rules relating to Pillar 2 have now been published by the OECD on Monday, 20 December. With this in mind, we are excited to announce that our Pillar 1 and Pillar 2 webinar will take place on Wednesday, 12 January from 16:00-17:30.
On 20 December 2021, the G20/OECD Inclusive Framework on BEPS ("inclusive framework") published Tax Challenges Arising from the Digitalisation of the Economy Global Anti-Base Erosion Model Rules (Pillar Two) ("model rules"). This follows on from the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, agreed by more than 135 of its members on 8 October 2021.
Since 2017, the 141 member countries of the inclusive framework have developed a "two-pillar" approach to address the tax challenges arising from the digitalization of the economy: addressing nexus and profit allocation challenges ("Pillar One") and global minimum tax rules ("Pillar Two").
The long-awaited model rules provide more clarity on the future of a global minimum tax rate. Although the model rules have now been published and confirm the key parameters, further clarification on certain aspects is still required. Additional details shall be provided in a commentary that is expected to be published by the OECD by the end of January 2022.
This week the council of the EU adopted the position on public CbC reporting paving the way for final approval on the EU directive by the parliament in November. This implies that EU public CbCR might become reality for multinationals as early as 2023.
The International Tax Review (ITR), is a world recognised authority and publisher for tax professionals in industry, government, private practice and research and have just awarded Deloitte Switzerland with the accolades of being the Swiss Tax Firm of the Year and the Swiss Transfer Pricing Firm of the Year for the 9th time.
Public Country-by-Country Reporting (CbCR): Corporations in the EU will have to disclose their profits and taxes in future & the US parliament puts forward a similar proposal
On Tuesday evening of last week, negotiators from the EU states and the European Parliament reached a preliminary agreement on the core of the new directive on “Public Country-by-Country Reporting”. The final approval of the Parliament and the Council of Ministers is considered a formality.
Similarly, on 12 May, the US parliament had brought forward a proposal that would direct the Securities and Exchange Commission (SEC) to require large publicly traded corporations to disclose certain tax and non-tax information on a country-by-country basis.