If cross-border arrangements lead to tax benefits without substance of economic benefits, these will become cross-borders to be reported.
Some Examples: acquisition of companies with tax losses; ownership in companies from jurisdictions not exchanging information; lack of economic substance of subsidiaries-lack of staff, equipment, assets, premises; transfer intangibles difficult to value; variance of projected EBIT for cross-border transfer of functions, assets and risk.
The mandatory action will enter into force starting 1st of July 2020 and will cover all arrangements in place after 25th of June 2018.
Our team of professional is available for any clarifications or additional details required in your analysis. The above information represents just a summary of aspects we consider relevant in the recently published legislation. This is not exhaustive disclosure of information and it is not intended to be used as advice on any particular matter. We invite all readers to contact us for further clarification of any specific issue. Argus Audit team and its associates disclaim liability in any action taken by a third party in reliance exclusively on summarized information presented in our publications.