Belgium may struggle to fulfil its CbC exchange commitments after technology trouble in the filing process, leaving non-resident affiliates that have relied on Belgian parties for filing unsure of what to do.
India’s 2018 budget introduced the idea of digital permanent establishment as the country aims to modernise tax laws for the digital age. Companies are now waiting to see how profit attribution rules for digital PEs will develop.
In dealing with the mandatory repatriation tax US multinationals have overcome the first wave of impact from the US tax reform. Now they are facing decisions over where to invest the money, with M&A and business model optimisation expected to take centre stage.
The introduction of transfer pricing legislation in Hong Kong will align the special administrative region with OECD standards, but could carry risks related to permanent establishments and audits.