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Global tax accounting
services newsletter
Focusing on tax
accounting issues
affecting businesses
today
July—September 2014
Global tax accounting services newsletter
Introduction
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Accounting and
reporting updates
Recent and upcoming major
tax law changes
Tax accounting refresher
Contacts and primary authors
Introduction
Andrew Wiggins
Global and UK Tax Accounting
Services Leader
+44 (0) 121 232 2065
[email protected]
The Global tax accounting services newsletter is a
quarterly publication from PwC’s Global Tax
Accounting Services Group. It highlights issues that
may be of interest to tax executives, finance
directors, and financial controllers.
In this issue, we provide an update on income tax
accounting topics added to the Financial
Accounting Standards Board’s (FASB) agenda,
amendments proposed to International Accounting
Standard 12 Income Taxes (IAS 12), the most
recent International Financial Reporting Standards
(IFRS) Interpretation Committee’s guidance on
some tax-related matters, and the country-bycountry reporting template presented by the
Organisation for Economic Co-operation and
Development (OECD) at the recent G20 meeting in
Australia.
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We also draw your attention to some significant tax
law and tax rate changes that occurred around the
globe during the quarter ended 30 September
2014.
Finally, we discuss key tax accounting and
reporting considerations in relation to transfer
pricing.
This newsletter, tax accounting guides, and other
tax accounting publications are also available on
our new TAS to Go app, which can be downloaded
globally via App Stores.
If you would like to discuss any items in this
newsletter, tax accounting issues affecting
businesses today, or general tax accounting
matters, please contact your local PwC team or the
relevant Tax Accounting Services network member
listed at the end of this document.
Readers should not rely on the information
contained within this newsletter without seeking
professional advice. For a thorough summary of
developments, please consult with your local PwC
team.
Global tax accounting services newsletter
Introduction
In this issue
Home Subscription
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Accounting and
reporting updates
Recent and upcoming major
tax law changes
Tax accounting refresher
Contacts and primary authors
In this issue
Accounting and reporting updates

Income tax accounting topics added to the FASB’s
agenda

Proposed amendments to IAS 12

The IFRS Interpretations Committee (IFRIC)
update

Country-by-country reporting
Recent and upcoming major tax law changes

Notable tax rate changes

Other important tax law changes
Tax accounting refresher

Tax accounting and reporting considerations in
relation to transfer pricing
Contacts and primary authors

Global and regional tax accounting leaders

Tax accounting leaders in major countries

Primary authors
Global tax accounting services newsletter
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Tax accounting refresher
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Accounting and reporting updates
This section offers insight into the most
recent developments in accounting
standards, financial reporting, and related
matters, along with the tax accounting
implications.
Income tax accounting topics
added to the FASB’s agenda
Overview
During its Agenda Prioritisation meeting on 13
August 2014, the Financial Accounting
Standards Board (FASB or Board) added the
following two income tax accounting topics to its
agenda as part of its broader simplification
initiative:

possible elimination of the exception for
recognising deferred taxes on certain
intercompany transactions under ASC 74010-25-3(e)

possible classification of all deferred tax
assets and liabilities as non-current
The Board also asked the staff to perform
additional research on potentially eliminating
the intraperiod tax allocation rules by having
income tax expense reported as a single line
item.
The Board also held a pre-agenda discussion
meeting on 10 September 2014 to provide
preliminary feedback to the staff on the research
project in relation to accounting for stock
compensation. The Board asked the staff to
perform additional research to consider various
alternatives with respect to the accounting for
tax benefit shortfalls and windfalls. The analysis
will include a comparison with the IFRS
treatment and will be presented in an upcoming
meeting, in which the Board will decide whether
to add these topics to its agenda.
In detail
On 13 August 2014, the FASB held a decisionmaking meeting with the purpose of prioritising
the Board’s upcoming technical agenda. The
Board voted on various topics throughout the
meeting. Consideration was given to several
potential topics related to income taxes which
could reduce complexity.
The push for the consideration of these topics
came from several sources. The sources included
feedback from the Financial Accounting
Foundation’s (FAF) Post-Implementation
Review completed November 2o13, an agenda
request submitted with respect to the
intercompany transaction exception, and
stakeholders’ ideas communicated in response to
the Board’s Simplification Initiative.
Continued
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The FASB staff performed additional research and
outreach on all of the above. The staff presented the
Board with specific topics relating to the following
eight areas of accounting for income taxes under
ASC 740:

intraperiod tax allocation

intra-entity transfers of assets

earnings determined to be indefinitely
reinvested in foreign subsidiaries

presentation of deferred tax accounts—
classification as current and non-current

balance sheet allocation of valuation
allowances

presentation of deferred tax accounts—
jurisdictional netting

valuation allowance estimates

backwards tracing
Many of the issues presented to the Board were
recently highlighted in PwC’s Point of view:
Accounting for income taxes – A case for
simplification. The Board voted to add two
income tax topics to the upcoming agenda and
requested that additional research be performed on
a third topic.
In addition to the topics discussed at the meeting,
the FASB staff noted that potential changes to
income tax disclosures would be considered as part
of the overall review of disclosures in the
Disclosure Framework Project.
Topics added to the FASB agenda
The Board agreed to add the possible elimination of
the exception for recognising deferred taxes on
certain intercompany transactions, specifically the
transfer of assets under ASC 740-10-25-3(e), to its
technical agenda. The FAF identified the exception
as an area that was challenging for preparers
during its Post-Implementation Review. The
exception does not exist under IFRS and was to be
eliminated as part of the ultimately abandoned
short-term tax convergence project.
Additionally, the Board added to its agenda
consideration of whether all deferred tax assets and
liabilities should be classified as non-current. The
Board noted that if this classification of deferred
tax assets and liabilities was adopted it would also
eliminate the complexity around the allocation of a
valuation allowance between current and noncurrent (a topic also presented by the staff).
Classification of all deferred taxes as non-current
would be consistent with IFRS.
Request for additional staff research
The Board asked the FASB staff to undertake
additional research to consider whether the FASB
should either have a separate project for possible
elimination of intraperiod tax allocation, or have
that be considered as part of a larger
comprehensive project on performance reporting.
The Board noted that the complexity around the
exception to the application of the intraperiod tax
allocation rules that applies when losses from
continuing operation offset gains in other
components, as well as the so-called ‘backwards
tracing’ (both presented by the staff), would no
longer be an issue if intraperiod tax allocation was
eliminated.
During its meeting on 10 September 2014, the
Board also asked the staff to perform additional
research on certain topics in relation to accounting
for stock compensation. These topics included:
Continued
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
possible elimination of the ‘windfall pool’
concept now used to determine the
classification of tax benefit ‘shortfalls’ by
recording all ‘windfalls’ and ‘shortfalls’ either
within equity or income tax expense

possible elimination of the current requirement
that cash taxes payable must be reduced before
the recording of a windfall tax benefit, and

possible elimination of the requirement to
display the gross amount of windfall tax
benefits as an operating outflow and financing
inflow in the cash flow statement
The analysis will include a comparison with the
IFRS treatment and will be presented in an
upcoming meeting, when the Board will decide
whether to add these topics to its agenda.
Items not added to the agenda
The Board decided to not make any changes to the
guidance for earnings determined to be indefinitely
reinvested in foreign subsidiaries.
Additionally, the Board decided against adding
topics associated with presenting deferred tax
assets and liabilities separately (i.e., removing
jurisdictional netting) and additional guidance for
assessing valuation allowances.
The steps recently taken by the FASB and the
ongoing efforts of the FASB staff may lead to
significant near-term improvements.
Organisations should continue to watch for further
developments as the FASB works through the tax
accounting topics along with those which will be
considered in the Disclosure Framework Project.
Takeaway
Accounting for income taxes continues to be a
complex, challenging area of financial accounting.
Users of financial statements continue to look for
decision-useful information on cash flows and risks
related to income taxes. Preparers and auditors
continue to struggle with the cost and complexity of
compliance.
Continued
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Proposed amendments to IAS 12
paid on maturity give rise to a deductible
temporary difference if this debt instrument is
measured at fair value and if its tax base
remains at cost. This applies irrespective of
whether the debt instrument’s holder expects
to recover the carrying amount of the debt
instrument by sale or by use (i.e., by holding it
to maturity), or whether it is probable that the
issuer will pay all the contractual cash flows.
Overview
On 20 August 2014, the International Accounting
Standards Board (IASB) published the Exposure
Draft on Recognition of Deferred Tax Assets
for Unrealised Losses (Proposed amendments
to International Accounting Standard 12 Income
Taxes (IAS 12)).
The Exposure Draft proposes guidance on how to
account for deferred tax assets related to debt
instruments measured at fair value when the fair
value of the instrument falls, creating unrealised
losses.

The issue originated from a submission to the IFRS
Interpretations Committee (IFRIC). In response,
the IFRIC recommended that the IASB should
amend IAS 12 (see the Q1 2014 newsletter for
the background).
Proposed guidance
The IASB proposes to confirm and clarify the
following:

Decreases in the carrying amount of a fixedrate debt instrument for which the principal is

The extent to which an entity’s estimate of
future taxable profit includes amounts from
recovering assets for more than their carrying
amounts will be clarified, i.e., future taxable
profit has to be probable to justify the
recognition of deferred tax assets. For example,
recovery of an asset for more than its carrying
amount is unlikely to be probable, if it was
recently impaired. On the other hand, the
recovery of an asset for more than its carrying
amount is likely to be probable, if it is
measured at cost and used in a profitable
operation.
An entity’s estimate of future taxable profit
excludes tax deductions resulting from the
reversal of deductible temporary differences.

An entity assesses whether to recognise the tax
effect of a deductible temporary difference as a
deferred tax asset in combination with other
deferred tax assets. If tax law restricts the
utilisation of tax losses so that an entity can
only deduct tax losses against income of a
specified type or specified types (e.g., if it can
deduct capital losses only against capital
gains), the entity must still assess a deferred
tax asset in combination with other deferred
tax assets, but only with deferred tax assets of
the appropriate type.
Application
The proposed amendments will have limited
retrospective application for entities already
applying IFRS. This is so that restatements of the
opening retained earnings or other components of
equity of the earliest comparative period presented
should be allowed but not be required.
Full retrospective application would be required for
first-time adopters of IFRS.
What’s next?
The Exposure Draft is open for comment until 18
December 2014. After considering the comments
the IASB will decide whether to proceed with the
proposed amendments to IAS 12.
Continued
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The IFRIC update
Overview
During the third quarter of 2014 the IFRIC
considered the following tax-related issues:

recognition and measurement of current
income tax on uncertain tax positions

recognition of deferred tax for a single asset in
a corporate wrapper
Below we outline the IFRIC’s conclusions on these
issues.
Recognition and measurement of current
income tax on uncertain tax position
The IFRIC received a request to clarify the
recognition of a tax asset in the situation in which
tax laws require an entity to make an immediate
payment when a tax examination results in an
additional charge, even if the entity intends to
appeal against the additional charge. In the
situation described by the submitter, the entity
expects, but is not certain, to recover some or all of
the amount paid. The IFRIC was asked to clarify
whether IAS 12 is applied to determine whether to
recognise an asset for the payment, or whether the
guidance in IAS 37 Provisions, Contingent
Liabilities and Contingent Assets should be
applied.
The IFRIC discussed this issue previously (see the
Q1 2014 newsletter) and during its meeting in
July 2014 decided that it should consider
separately the question of recognition and the
question of measurement of assets and liabilities in
the situation in which tax position is uncertain.
Recognition
The question of recognition of assets and liabilities
in the situation in which tax position is uncertain
was discussed by the IFRIC in July 2014. The
IFRIC noted that:

Paragraph 12 of IAS 12 provides guidance on
the recognition of current tax assets and
current tax liabilities. In particular, it states
that:
a) current tax for current and prior periods
shall, to the extent unpaid, be recognised
as a liability; and
b) if the amount already paid in respect of
current and prior periods exceeds the
amount due for those periods, the excess
shall be recognised as an asset.

In the specific fact pattern described in the
submission, an asset is recognised if the
amount of cash paid (which is a certain
amount) exceeds the amount of tax expected to
be due (which is an uncertain amount).

The timing of payment should not affect the
amount of current tax expense recognised.
The IFRIC understood that the reference to IAS 37
in paragraph 88 of IAS 12 in respect of tax-related
contingent liabilities and contingent assets may
have been understood by some to mean that IAS 37
applied to the recognition of such items. However,
the IFRIC noted that paragraph 88 of IAS 12
provides guidance only on disclosures required for
such items, and that IAS 12, not IAS 37, provides
the relevant guidance on recognition, as described
above.
On the basis of this analysis, the IFRIC noted that
sufficient guidance exists. It concluded that the
agenda criteria are not met and decided to remove
from its agenda the issue of how current income
tax, the amount of which is uncertain, is
recognised.
Continued
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Measurement
The IFRIC noted that one of the principal issues in
respect of uncertain tax positions is how to
measure related assets and liabilities.
During its meeting in July 2014, the IFRIC asked
the staff to prepare a discussion paper that analyses
the question of how to measure assets and
liabilities in the situation in which tax position is
uncertain. In particular, the IFRIC asked the staff
to analyse how detection risk and probability
should be considered in the measurement of tax
assets and liabilities in such situations.
During its meeting in September 2014, the IFRIC
discussed several aspects of measurement of assets
and liabilities on uncertain tax positions. It
tentatively decided to proceed with this project,
subject to further analysis and deliberations. In
particular, the IFRIC requested the staff to prepare
a proposal with respect to:

the scope of the project

the unit of account for measurement of
uncertain tax positions

the possible approach for the measurement
method(s). The IFRIC considered that the
approach taken by the IASB and the FASB,
when they had developed IFRS 15 Revenue
from Contracts with Customers, could be
relevant when developing the proposal on
measurement method(s)
The IFRIC noted that:

Paragraph 11 of IAS 12 requires the entity to
determine temporary differences in the
consolidated financial statements by
comparing the carrying amounts of assets and
liabilities in the consolidated financial
statements with the appropriate tax base. In
the case of an asset or a liability of a subsidiary
that files separate tax returns, this is the
amount that will be taxable or deductible on
the recovery (settlement) of the asset (liability)
in the tax returns of the subsidiary.

The requirement in paragraph 11 of IAS 12 is
complemented by the requirement in
paragraph 38 of IAS 12 to determine the
temporary difference related to the shares held
by the parent in the subsidiary by comparing
the parent’s share of the net assets of the
subsidiary in the consolidated financial
statements, including the carrying amount of
goodwill, with the tax base of the shares for
purposes of the parent’s tax returns.
The IFRIC also discussed whether detection risk
should be reflected in the measurement of tax
assets and liabilities arising from uncertain tax
positions. It concluded that an entity should
assume that the tax authorities would examine the
amounts reported to them and have full knowledge
of all relevant information (i.e., it should assume a
100% detection risk).
The staff will present the additional analysis
requested by the IFRIC at a future meeting
(expected to be in November 2014).
Recognition of deferred tax for a single
asset in a corporate wrapper
The IFRIC received a request to clarify the
accounting for deferred tax in the consolidated
financial statements of the parent, when a
subsidiary has only one asset within it (the asset
inside) and the parent expects to recover the
carrying amount of the asset inside by selling the
shares in the subsidiary (the shares).
Continued
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The IFRIC also noted that these paragraphs require
a parent to recognise both the deferred tax related
to the shares and the assets within the subsidiary,
if:

tax law attributes separate tax bases to the
asset inside and to the shares

in the case of deferred tax assets, the related
deductible temporary differences can be
utilised as specified in paragraphs 24-31 of IAS
12; and

no specific exceptions in IAS 12 apply
The IFRIC noted that several concerns were raised
with respect to the current requirements in IAS 12.
However, analysing and assessing these concerns
would require a broader project than the IFRIC
could perform on behalf of the IASB.
Consequently, the IFRIC decided not to take the
issue onto its agenda but instead to recommend to
the IASB that it should analyse and assess these
concerns in its research project on Income Taxes
(updates in relation to the status of the project will
be posted on the IFRS site here).
Contacts and primary authors
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Accounting and reporting updates
Country-by-country reporting
Overview
On 16 September 2014, the OECD released the final
template for country-by-country reporting (CBCR
template) and a number of other reports on the
Base Erosion and Profit Shifting (BEPS) Action
Plan.
The CBCR template was adopted by the OECD’s
Committee on Fiscal Affairs on 25-26 June 2014
after months of work by OECD staff,
representatives of the Revenue Authorities of the
OECD and certain non-member countries in
working parties. Consultations also took place with
input from other, particularly developing, countries
and various supranational bodies including the
European Commission, United Nations and
International Monetary Fund as well as business
and civil society organisations.
reported for all tax jurisdictions in which a
multinationals subject to tax are:
During their meeting in Australia on 20-21
September 2014, Finance Ministers of the G20
countries accepted the CBCR template and
committed to finalising all action items in 2015.

revenues (from both related and unrelated
party transactions)

profit before income tax

income tax paid (cash basis)

current year income tax accrual

stated capital

accumulated earnings

number of employees

tangible assets (excluding cash and
equivalents)
In detail
As mentioned in the Q2 2014 newsletter, the
CBCR template will be a separate document from
the transfer pricing master and local files. The
country-by-country information is to be reported to
tax authorities at a high level and for risk
assessment purposes only.
There are a few substantive changes from the
earlier draft released by the OECD in January 2014.
The report now confirms that the data points to be
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It appears that the template is designed to highlight
those low-tax jurisdictions where a significant
amount of income is allocated without some
‘proportionate’ presence of employees. What this
means in practice is that there will be pressure to
assure that profit allocations to a particular
jurisdiction are supported by an appropriately
qualified number of employees who are able to
make a ‘substantial contribution’ to the creation
and development of intangibles.
There remain concerns regarding the
confidentiality of this data and, despite guidance
from the OECD to the contrary, the potential for
adjustments by tax administrations based on a
formulary apportionment approach leading to
many more transfer pricing controversies.
The OECD also noted that some countries (for
example, Brazil, China, India, and other emerging
economies) would like to add further data points to
the template such as interest, royalty, and related
party service fees. These data points will not be
included in the template at this point, but the
OECD has agreed that they will review the
implementation of this new reporting by 2020 and
decide whether there should be additional or
different data reporting. A concern in this context
is that there may well be a desire to expand CBCR,
particularly in developing countries. That is, the
emerging market economies that implement CBCR
could well require the reporting of interest, royalty,
and related party service fees. They could also
require CBCR for any company doing business in
their jurisdiction, regardless of where the
multinational parent entity is located. The
availability of the data to requesting countries will
also be considered in the OECD’s review of the
implementation of CBCR.
and filing issues and report on these matters at the
beginning of 2015.
The OECD does not yet have absolute consensus on
the arrangements for the sharing of country-bycountry information although they are seeking to
finalise these arrangements by January 2015. This
would include confidentiality issues with
indications that information will only be exchanged
pursuant to treaty or tax information exchange
agreement provisions.
Takeaway
What’s next?
The CBCR template will be presented to the G20
Leaders meeting in Brisbane in November 2014.
As mentioned in the Q2 2014 newsletter, the
OECD will continue to work on implementation
For many OECD countries there may be a need to
implement CBCR through changes to domestic law
before it could fully come into effect. However, it is
clear that there is a strong commitment from
countries to implement CBCR. In fact, on 20
September 2014 the UK became the first country to
formally commit to implementing the CBCR
template.
Taxpayers will need to take account of the speed of
the above developments, as well as the work which
remains in progress, as they frame their response.
Given the lead time generally required to prepare
internal systems and processes for CBCR and the
level of funding and change that may be required, it
is critical that taxpayers begin to assess now
whether their current information and accounting
systems will allow them to comply with the above
CBCR requirements and with any subsequent
information requests from tax authorities.
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Recent and upcoming major tax law changes
This section focuses on major changes in the
tax law that may be of interest to multinational
companies and can be helpful in their tax
accounting considerations. It is intended to
increase readers’ awareness of the main global
tax law changes during the quarter, but does
not offer a comprehensive list of tax law
changes that should be considered for
financial statements.
Notable enacted tax rate changes
Country
Australia (carbon tax)
Australia (minerals resource
rent tax)
Bangladesh (CIT)
Egypt (tax on capital gains
and stock dividends)
France (surtax)
Prior rate
New rate
AU$24.15 per tone
N/A 1
22.5% (effective rate)
N/A2
37.5%
35%3
N/A
10%4
10.7%
10.7%5
1 Carbon
tax was fully repealed effective from 1 July 2014. The repeal was enacted on 17 July 2014.
resources rent tax was repealed effective 1 October 2014. The repeal was enacted on 5 September 2014.
3 This change was enacted on 1 July 2014 and is effective from that date.
4 A new 10% tax is imposed in Egypt on dividends and capital gains. This tax was enacted on 1 July 2014 and is effective from that
date.
5 On 6 August 2014, France enacted a one-year extension of the 10.7% surtax on corporate income tax (resulting in a maximum
corporate income tax rate of 38%) until 30 December 2016. This means that December year-end companies will be subject to the
increased surtax until 31 December 2015.
2 Mineral
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Other important tax law changes
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Recent and upcoming major tax law changes
Australia
During the third quarter of 2014, the following tax
measures were repealed in Australia:




There will be two alternate methods of income
taxation at the shareholder level:
-
deduction for exploration expenditure for
geothermal energy (effective from 1 July 2014)
immediate deduction for certain depreciable
assets held by small business (effective from 1
January 2014)
loss carry-back rules (effective from 1 July
2013)
Canada
During the third quarter of 2014, Canada
introduced a legislative proposal to implement
certain 2014 budget measures (see the Q1 2014
newsletter).
Chile
During the third quarter of 2014, the tax reform bill
in Chile (see the Q1 2014 newsletter) was
enacted with the following significant
amendments:
-

Shareholder taxation on an ‘attribution’
basis, i.e., shareholder taxation will be
imposed on income attributed as of the end
of the taxable year in which it is generated.
The underlying corporate income tax paid
at the entity level will remain creditable for
all taxpayers against the final shareholder’s
tax, such that the total income tax burden
in Chile will remain at 35%.
Shareholder taxation on a ‘cash basis’, i.e.,
an optional method of taxation which will
impose a 27% corporate-level income tax
(CIT) rate and an additional 35% tax on
cash distributions to shareholders.
Generally, 65% of the CIT rate will be
creditable against the 35% additional tax
(as opposed to 100% under the current
rules). However, for shareholders resident
in jurisdictions that have a tax treaty in
force with Chile, the underlying CIT will be
fully creditable against the 35% additional
tax.

The corporate-level income tax rate will
increase gradually from the current rate of
20%, as follows:
-
21% for 2014
-
22.5% for 2015
-
24% for 2016
-
25% for 2017 for shareholders taxed on the
‘attribution’ method; or, 25.5% for
shareholders on the ‘cash basis’ method
-
25% for 2018 and future years for
shareholders taxed on ‘attribution’ method;
or, 27% for shareholders on the ‘cash basis’
method
In general, foreign shareholders will be subject
to a 35% tax on capital gains that are
recognised in connection with the sale or other
transfer of Chilean shares. Previously, such
capital gains could have been subject to either a
20% or 35% tax rate depending on certain
requirements.
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Recent and upcoming major tax law changes


The general anti-avoidance rules apply only to
transactions entered into after the law’s
enactment.
Tax legislation affecting goodwill has been
amended to deny goodwill amortisation and
treat it as a non-deductible intangible for
Chilean income purposes.

Previously proposed restriction on the
deductibility of interest on loans entered into
to finance the acquisition of stock has been
removed. Such interest will be deductible,
subject to certain conditions.

A grandfathering provision has been
introduced to the thin capitalisation
amendments. The provision covers loans
entered into before the law was enacted.

Previously proposed controlled foreign
company rules, including their entry into force,
have been amended.

The criteria under which a jurisdiction is
deemed a ‘tax haven’ have been amended.

The preferential tax treatment of free trade
zones has been preserved.
China
Hong Kong
During the third quarter of 2014, China’s State
Administration of Taxation released a discussion
draft on Administrative Measures on the General
Anti-Avoidance Rule (GAAR) for public
consultation.
During the third quarter of 2014, Hong Kong
enacted a tax provision that waives 75% of profits
tax for 2013/14 subject to certain conditions.
The draft provides that a ‘tax avoidance scheme’
that is intended to obtain a tax benefit without
reasonable commercial purpose shall be subject to
a GAAR adjustment, and clarifies the main
characteristics of a ‘tax avoidance scheme.’ It also
sets out some important principles in the
application of GAAR, and stipulates the adjustment
methods where GAAR is triggered, and the relevant
GAAR investigation procedures.
France
During the third quarter of 2014, the French tax
authorities released final guidelines regarding
the legislation enacted on 30 December 2013,
targeting hybrid mismatch arrangements. The final
guidelines confirm that disallowed interest will not
be treated as a deemed distribution.
Hungary
During the third quarter of 2014 a Hungarian
government’s decree on the development
tax incentive was enacted. Companies once again
may claim the development tax incentive for their
investment projects. The new decree is designed to
align Hungary’s development tax incentive rules
with the European Commission’s new guidelines on
regional state aid and a new General Block
Exemption Regulation for the European Union
(EU) budgetary period 2014-2020.
India
During the third quarter of 2014, measures
announced in the Indian Budget 2014 were
enacted in India. These included the following key
corporate tax changes:

There will be no deferral of the general antiavoidance rules. These rules should become
effective 1 April 2015.
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
Income arising from transactions in securities
(including derivatives) of foreign institutional/
portfolio investors will be treated as capital
gains (as opposed to business income).

Unlisted securities and mutual fund units
(other than equity-oriented funds) will need to
be held for 36 months (previously 12 months)
in order to qualify as a long-term capital asset.

The concessional 5% withholding tax rate has
been extended for foreign loan agreements
entered into before 30 June 2017 (previously
30 June 2015).

The base for calculating Dividend Distribution
Tax (DDT) has been changed from ‘dividends
distributed’ to ‘distributable profits’. With this
change, the effective DDT rate has increased
from 17% to approximately 20.5%. This
increases the cost of profits repatriation by
Indian subsidiaries.

Entities in the power sector that commence
generation, distribution, and transmission
before 31 March 2017 (presently 31 March
2014) will be eligible for a 10-year tax holiday.

The transfer of government securities, carrying
a periodic payment of interest, between two
non-Indian residents outside India will be
exempt from capital gains tax in India (subject
to meeting certain conditions).
In addition, during the third quarter of 2014 the
Delhi High Court issued a landmark ruling
regarding the application of the Indian
indirect transfer taxation provisions
introduced in 2012 (those provisions followed the
high-profile Vodafone case). These provisions
specify that gains arising from the transfer of
shares of a company incorporated outside India is
taxable in India if the company’s shares derive their
value ‘substantially’ from assets located in India.
The definition of ‘substantially’ was not included in
the act, but has now been clarified by the Delhi
High Court. The Court ruled that if 50% of an
offshore company’s share value is derived from
assets located in India this qualifies as
‘substantially’ for purposes of the indirect transfer
tax provisions.
Mexico
During the third quarter of 2014, the Mexican tax
authorities enacted amendments to the Mexican
Miscellaneous rules in force for 2014. These
amendments introduce certain changes and
clarifications to the Maquiladora regime that could
affect Maquiladora entities that carry on certain
auxiliary activities. In general, the new rules
introduce more flexibility to the concept of
‘productive’ income and allow Maquiladora entities
to engage in certain ‘complementary’ activities
without jeopardising their qualified status.
Nigeria
During the third quarter of 2014 the Nigerian
Federal Inland Revenue Service (FIRS)
announced that it would no longer accept income
tax returns filed by non-resident companies doing
business in Nigeria unless the returns were
accompanied by audited financial statements and
tax and capital allowance computations.
During the quarter the Nigerian Tax Appeal
Tribunal (TAT) ruled that upstream companies
may deduct interest charges on related-party loans,
provided the loans are obtained at arm’s length.
The ruling was issued in a case brought before the
TAT by an upstream oil and gas company against
the Federal Inland Revenue Service. The decision
provides clarity on the controversial issue of the
deductibility of interest on related-party loans.
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Poland
19% income tax in Poland. However, a foreign
company would not be subject to CFC
regulations if its annual income does not
exceed euro 250,000.
During the third quarter of 2014, the following tax
measures were proposed in Poland:

The following amendments would be
made to Polish thin capitalisation rules:
-
The scope of the thin capitalisation rules
would be expanded to a much broader
group of related parties.
-
The amount of interest that is tax
deductible would be significantly limited.
The current 3:1 debt-to-share capital ratio
limit would be reduced to 1:1. However, the
amount of the debt would be compared to
the amount of the borrower’s equity
instead of the share capital as prescribed
by the current rules.
-

An optional method for calculating the
deductible interest limit would be
available.
A controlled foreign corporation (CFC)
taxation regime would be introduced. Under
this regime the income earned by a CFC or a
permanent establishment should be subject to
Qatar
During the third quarter of 2014, the limit on
foreign ownership of Qatar Stock Exchange (QSE)
listed companies was increased to 49% (previously
the foreign ownership limit in most listed
companies was 25%). This could result in increased
foreign investor activity in the near future.
Slovakia
South Korea
During the third quarter of 2014, the following tax
measures were proposed in South Korea:

Additional 10% tax would apply to excessive
corporate reserves, i.e., corporate income not
used for investments, wages, and dividends.

Ten percent tax credit (5% for large
corporations) on the incremental amount in
average corporate payroll over the average
corporate payroll of the previous three years
would be available.

Thin capitalisation rules would be tightened as
follows:
During the third quarter of 2014, the following tax
measures were proposed in Slovakia:

Thin capitalisation limit of 25% of EBITDA
would be introduced for interest on loans
provided by foreign related parties.

Deductibility of expenses related to ‘luxury’
goods would be limited (e.g., deductibility of
car depreciation expenses would be limited to
euro 48,000).

-
the borrowing ceiling which was three
times (six times for financial institutions)
the equity, would be lowered to two times
the equity (ceiling for financial institutions
would remain unchanged)
-
the scope of the rules would be expanded
to include relatives of foreign controlling
shareholder
The statute of limitation for a tax refund
request would be extended from three years to
five years.
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Spain

During the third quarter of 2014, the Spanish
government amended draft bills relating to
a tax reform released in June 2014. These bills
are now with the Parliament for approval.
The draft bills’ principal changes include the
following:


Requirements for the participation
exemption regime would be clarified. In
particular, taxpayers would meet the direct
or indirect 5% subsidiary ownership
requirement if the investment in the
subsidiary is at least euro 20 million (down
from euro 50 million in the previous draft).
Interest deductibility limits would be
modified in relation to debt assumed for the
acquisition of an entity that joins the buyer’s
tax consolidated group. Under the new
provision, that limit would not apply in the
acquisition year if the acquisition is not
more than 70% debt-financed, and would
not apply in subsequent years in which at
least 5% of the debt is eliminated until a year
in which the debt amounts to no more than
30% of the acquisition price.
Non-resident income tax regime would be
modified. In particular, the new draft
clarifies that the participation requirement
in the Spanish subsidiary (5%) would be met
when the acquisition value of the Spanish
entity exceeds euro 20 million. Similarly, for
the exemption on royalties paid to EUassociated entities to apply, an EU entity
direct or indirectly owned by a non-EU
resident would need to be incorporated for
valid economic and substantive business
reasons.
Switzerland
During the third quarter of 2014, the Swiss
Federal Council published the draft legislative
text of the Federal Law on Measures to
Maintain the Competitiveness of Business
Location Switzerland (Law on Swiss
Corporate Tax Reform III or CTR III). This
draft will be open for comments until 31 January
2015.
The key points of the consultation draft include
the following:

The current privileged cantonal tax regimes
would be replaced with more internationally
acceptable measures.

Some of the cantonal income tax rates would
be decreased.

Further measures would be introduced to
increase the competitiveness of Swiss tax
law.
Ukraine
During the third quarter of 2014, a law was
enacted in the Ukraine that would eliminate
certain corporate tax incentives from the
country’s tax code. In particular:

Taxable gains on the sale of securities will be
subject to the standard corporate income tax
rate of 18% instead of the reduced rate of
10%.

The corporate income tax exemption for
profits of investment funds no longer will
apply to interest income of such funds.

Power-generating companies that receive
profits from the generation of electric energy
from renewable energy sources, as well as
three-, four-, and five-star hotels, no longer
will be entitled to the corporate income tax
exemption.
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United Kingdom
United States
During the third quarter of 2014, the following
2013 Budget proposals were enacted in the UK:
During the third quarter of 2014, the Internal
Revenue Service (IRS) issued final regulations
on the Section 174 deduction for research and
experimentation (R&E) expenditures (T.D. 9680)
that adopt, with certain modifications, the
proposed regulations issued in September 2013.

Tax breaks were introduced for Shale gas field
allowances.

Changes were made to the grouping rules for
the UK debt capitalisation rules.

Restrictions for utilisation of trading losses due
to changes in corporate ownership were
relaxed.

Annual investment allowance (100% capital
allowanced on plant) was increased to GBP
500,000.
The IRS also issued Notice 2014-44 to provide
guidance regarding the application of the socalled disposition rule under Section 901
(m).
The IRS also released final regulations under
Section 168 regarding disposals of tangible
depreciable property, which modify the proposed
disposition regulations that were issued in
September 2013.
During the third quarter of 2014, the Treasury
Department and the IRS issued final Section 861
regulations (TD 9676) regarding the allocation
and apportionment of interest expense. These final
regulations finalise temporary and proposed
regulations without substantive change and do not
make major modifications to the existing
regulatory scheme.
The Treasury Department and the IRS also issued
their 2014/2015 Priority Guidance Plan,
including projects in relation to subpart F, inbound
and outbound transactions, foreign tax credits and
currency exchange regulations. In general, some
projects are completed in the first year they appear
on the business plan. Others carry over for several
years while the Treasury and the IRS address other
priorities or try to resolve technical or policy issues.
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In this section we discuss key tax
accounting considerations in relation to
transfer pricing and highlight several
important areas of financial reporting that
can be affected by transfer pricing.
Tax accounting and reporting
considerations in relation to
transfer pricing
Overview
The topic of transfer pricing as it pertains to tax
accounting and reporting is often associated with
uncertain tax positions — that is, the extent to
which tax reserves may need to be recorded due to
uncertainty with tax return positions. However,
other areas should also be considered, including
valuation allowances, measuring deferred taxes on
foreign earnings, business restructuring,
presentation of tax information in financial
statements and disclosures.
These and other key tax accounting and reporting
considerations associated with transfer pricing are
discussed below.
Uncertain tax positions
US GAAP Accounting Standards Codification 740,
Income Taxes (ASC 740), provides guidance for
recognising and measuring positions taken or
expected to be taken in a tax return that directly or
indirectly affect amounts reported in a company’s
financial statements. The guidance provides a two-
step model: Step 1 – A tax benefit is recognised
only if it is more likely than not sustainable based
upon its technical merits; and Step 2 – The tax
benefit recognised is measured as the greatest
amount that is more than 50% likely to be realised
upon settlement with the taxing authority.
Amounts unrecognised are often known as tax
reserves.
The application of this accounting model requires
significant judgment and is dependent upon the
facts and circumstances. In some cases, tax
positions arising from intercompany transactions
may require assessment to determine whether the
recognition threshold (Step 1) is met. Most transfer
pricing positions, however, are considered to meet
the recognition threshold; the uncertainty relates to
the transaction’s valuation or pricing, which is
addressed in the measurement process (Step 2).
Under IFRS IAS 12, when it is probable that an
entity has incurred a liability, such liability is
measured using either a weighted average
probability approach, or at the single best estimate
of the most likely outcome. The probability
threshold under IAS 12 is generally interpreted as
‘more likely than not’, similar to ASC 740.
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As mentioned in the accounting and reporting
update section of this newsletter, the question of
measurement of assets and liabilities in the
situation in which tax position is uncertain is
currently being considered by the IFRIC. The
IFRIC asked the staff to analyse how detection risk
and probability should be considered in the
measurement of tax assets and liabilities in
uncertain situations and present their conclusions
at a future IFRIC meeting.
Determining the appropriate valuation or transfer
price often leaves uncertainty. A transfer pricing
analysis may produce a range of appropriate
outcomes, yet the measurement process requires a
company to determine which single outcome
represents the greatest amount that is more than
50% likely (i.e., more likely than not threshold) to
be accepted by the taxing authority.
The assessment of transfer pricing uncertainty
should include consideration of the relevant tax
laws, tax treaties, and any arrangements
established with taxing authorities. Advance
pricing agreements (APAs) may help mitigate or
alleviate a company’s risk that its transfer pricing
arrangement will be subject to challenge. Even
when transfer pricing falls within an arm’s length
range that is properly documented by the taxpayer,
it may be appropriate for a company to record a
reserve in its financial statements. This may occur
when a company expects it will ultimately settle
with the taxing authority at some other amount. In
measuring the reserve to record, companies may
need to consider the results of alternative transfer
pricing methods in their analysis.
Once all relevant information is identified and
assessed, consideration should be given to the
impact an uncertain transfer pricing position may
have in other tax jurisdictions. An uncertain
position taken in one jurisdiction may give rise to a
corresponding tax position reducing taxable
income in another jurisdiction where an affiliate
resides. ASC 740 and, similarly, IAS 12 prohibit the
offsetting or netting of a reserve in one jurisdiction
against a potential tax overpayment (or receivable)
in a separate jurisdiction. Companies should assess
and record both the income tax liability and any
potential asset separately (on a gross basis) in the
financial statements. In some instances, the
recording of an uncertain tax position may impact
the amount of other taxes due.
When a company is under examination by a taxing
authority, the status of the exam must be
monitored continually to assess potential financial
reporting changes. To the extent new information
arises, a company must consider whether there
should be a re-measurement of benefits. Impact of
any re-measurement should be taken into account
in the period when it occurs.
Reserves for positions taken in tax years that are
not examined, and any corresponding assets
recorded for other jurisdictions, would be reversed
when the relevant statute of limitations expires.
Valuation allowance
An inherent assumption within the financial
accounting model for income taxes is that the
reported amounts of assets and liabilities reflected
in a company’s financial statements will ultimately
be recovered or settled.
Under IAS 12, deferred tax assets are recognised to
the extent that it is probable (i.e., ‘more likely than
not’) that sufficient taxable profits will be available
to utilise the deductible temporary difference or
unused tax losses. Valuation allowances are not
allowed to be recorded. However, the amount (and
expiry date, if any) of unprovided deferred tax
needs to be disclosed.
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ASC 740 requires companies to weigh all available
evidence to determine whether all or some portion
of deferred tax assets will be realised, and establish
a valuation allowance when it is more likely than
not that the assets will not be realised. It was
previously confirmed by the IASB and the FASB,
that there are no differences in the ‘more likely
than not’ threshold under IFRS and US GAAP.
deferred tax assets. Provided the adjusted transfer
price continues to fall within the arm’s length range
and is economically prudent, the change may
constitute objective positive evidence supporting
realisation of a company’s deferred tax assets. For
companies that have APAs, the evidence may be
strengthened by what is effectively third-party
(taxing authority) verification.
Evidence to be considered with respect to each tax
jurisdiction includes historical information
supplemented by information about future taxable
income that is currently available. Forming a
conclusion that a valuation allowance is not needed
can prove challenging when there is negative
evidence such as cumulative losses in recent years.
For deferred tax assets in a jurisdiction in which
significant revenues or costs arise from
intercompany transactions, transfer pricing can be
a key focal point.
Another source of taxable income for companies to
consider when evaluating the realisability of
deferred tax assets is tax reserves. For
multinational companies with reserves for transfer
pricing uncertainties, consideration should be
given to whether settlement of the reserves would
constitute a source of taxable income. That may
depend on the period(s) in which additional taxable
income would be reported in the relevant tax
jurisdiction.
The need for a valuation allowance may be
overcome by the existence of sufficient future
taxable income, which can be directly affected by
transfer pricing arrangements. For example, a
company may have flexibility to adjust its existing
transfer pricing and allocate a greater percentage of
profit to a jurisdiction with recent losses and
Measuring deferred taxes on foreign
earnings
ASC 740 presumes that the undistributed earnings
of a foreign subsidiary will ultimately be
repatriated to the parent company. Under this
general presumption, companies based in
jurisdictions that apply a worldwide system of
taxation (such as the United States) would record a
home country deferred tax liability on the ‘outside
basis’ difference in a foreign subsidiary. The
outside basis difference represents the difference
between a parent’s book and tax basis in a
subsidiary, often including undistributed foreign
earnings, currency translation, and other
accounting adjustments. An exception, if met,
allows a company to overcome the presumption
that foreign earnings will be repatriated and forgo
the recording of a tax liability for some or all of the
outside basis difference.
Under IAS 12, an entity shall recognise a deferred
tax liability for all taxable temporary differences
associated with investments in subsidiaries,
branches and associates, and interests in joint
arrangements, except when a parent company is
able to control the timing of reversal of the
temporary difference, and it is probable that the
temporary difference will not reverse in the
foreseeable future.
For companies that record a deferred tax liability
on the outside basis difference (i.e., investment in a
subsidiary), consideration should be given to the
impact of transfer pricing on the deferred tax
calculation (for companies not recording a deferred
tax liability, transfer pricing can impact the
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estimate of the unrecorded tax that may be
disclosed). Transfer pricing will affect, for example,
the amount of foreign taxes due in a given
jurisdiction and the respective foreign tax credit
that would arise upon repatriation. This might
include foreign tax reserves recorded as a result of
transfer pricing uncertainty. Transfer pricing can
also affect the amount of taxable income that will
result upon repatriation, as well as from categories
of income that are ineligible for home country
deferral (such as ‘Subpart F income’ under US tax
law).
The computation of a company’s outside basis
difference can also include book-tax differences
associated with stock-based compensation.
Consideration should be given to whether a parent
and foreign subsidiary’s transfer pricing
arrangements include the sharing of costs
associated with stock-based compensation awards.
If so, it may in effect give rise to a tax benefit that
may need to be considered. In some circumstances,
stock-based compensation awards can also reduce
the outside basis difference, and thereby the
measurement of the deferred tax liability.
Business restructuring
Multinational companies often undertake internal
restructurings of their business operations. This
can involve cross-border redeployment of assets,
risks, and functions, all of which implicate transfer
pricing. The accounting impact of restructurings
can include tax consequences in both the
transferring and receiving jurisdictions.
Under US GAAP, the income tax effects resulting
from intercompany transfers of assets are generally
not recognised immediately in the consolidated
financial statements. Specifically, Consolidation
subtopic ASC 810-10-45-8 defers taxes paid on
intercompany profits on assets remaining within
the consolidated group, and ASC 740-10-25-3(e)
prohibits the recognition of a deferred tax asset for
basis differences related to the intercompany
profits (please note, the FASB is to consider
whether the exception for recognising deferred
taxes in certain intercompany transactions should
be eliminated (see ‘Income tax accounting topics
added to FASB’s agenda’ above)). If the
arrangement constitutes the transfer of an asset,
any net income tax consequences of the transfer are
generally deferred and amortised to income over
the period of economic benefit.
Under IFRS, any current and deferred taxes
associated with intercompany transfers should be
recognised at the time of the transaction. A
temporary difference usually arises on
consolidation as a result of retaining the pretransaction carrying amount of the transferred
asset while having its tax base according to the
intragroup transaction price.
A deferred tax asset may also need to be recognised
under IFRS, if under a ‘special tax ruling,’ a tax
asset (e.g., a deemed intangible) is generated on the
transfer of functions or assets of an entity, and this
tax asset is depreciable for tax purposes. Under US
GAAP no deferred tax asset may be recognised in
this situation due to the above exemption.
Companies reporting under US GAAP should take
care in determining the extent to which the deferral
mentioned above applies — for example, whether
the deferral would apply to any ‘exit taxes’. An exit
tax may be imposed based on the value of assets
deemed transferred to a different tax jurisdiction,
or perhaps on the value of forgone future profits.
The deferral principle would apply only to an exit
tax that is considered a tax based on income. The
deferral may also apply to uncertain income tax
positions, such as uncertainty relating to the value
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of assets transferred. For companies not asserting
indefinite reinvestment, the deferral may apply to a
resulting re-measurement of the deferred tax
liability.
Internal restructurings may involve a change in tax
status for one or more of the entities involved, such
as from non-taxable to taxable or vice versa. ASC
740 requires the tax effects of a change in tax status
to be included in income from continuing
operations at the date the change occurs. The
deferral principle discussed above would not apply
to these tax effects. A change in tax status is
typically considered to occur on the date when
approval is obtained for elective changes or the
date the filing or election is made if approval is not
required.
Separate company financial statements
Businesses that prepare consolidated (or group)
financial statements also often prepare separate
financial statements for one or more subsidiaries or
other business units. The preparation of separate
company financial statements may arise from
internal business needs, but often serve to meet the
external requirements of regulators, investors,
creditors, and tax authorities.
Intercompany transactions that were eliminated in
the consolidated financial statements must often be
reported in separate financials and adequately
disclosed to ensure readers have decision-useful
information. When related-party transactions
represent a significant part of recurring operations
between the separate reporting members and
affiliates in the broader reporting group, a transfer
pricing analysis could be a relevant factor to
consider with respect to the measurements of pretax revenues or costs from those transactions.
Accordingly, measurement of revenues and costs
would be assessed for reasonableness and
consistency with a company’s transfer pricing
methodologies. This may extend to intercompany
transactions that are reported in a consolidated tax
return with members of the broader reporting
group. If transfer pricing methodologies were not
previously established, an appropriate analysis may
be warranted to support the separate company
statements. Terms set forth in APAs would
represent third-party evidence to be considered in
measuring pre-tax revenues and costs. The
respective income tax accounting would be applied
based on the measurements recorded in the
standalone pre-tax accounts.
Consideration should also be given to tax reserves
and settlements with taxing authorities relating to
transfer pricing. For companies with APAs,
reserves may need to be considered in separate
company statements when the business results fall
outside the range of the agreed-upon financial
metric. Tax reserves or settlements may give rise to
an expectation (or agreement) with the related
party to make a compensating payment or pricing
adjustment. Whether such payments or
adjustments are recorded in equity or the income
statement will depend upon the facts and
circumstances.
Other areas
The impact of transfer pricing in financial reporting
extends to other areas as well, including interim
reporting, mergers and acquisitions, and
disclosures.
Interim reporting
The calculation of a company’s estimated annual
effective tax rate (AETR) should reflect a
company’s transfer pricing policies. Specifically,
the calculation should include related-party
transactions in the annual projections of pre-tax
earnings, and the appropriate jurisdictional tax
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rates applicable to those transactions. For example,
intercompany sales revenue should be allocated to
the appropriate tax jurisdictions (e.g., foreign,
domestic, state, and local) in accordance with a
company’s transfer pricing arrangements, and the
appropriate tax rates and apportionment
percentages applied. Any required tax reserves
relating to current-year transactions should be
included in the AETR calculation. Throughout the
course of the year, as the intercompany
transactions change in volume or shift across
jurisdictions, companies should update their AETR
estimates accordingly.
Mergers and acquisitions
When determining the appropriate book and tax
values of assets acquired and liabilities assumed in
a business combination, transfer pricing may play
an important role. For example, in a taxable
acquisition (wherein tax bases are adjusted to the
purchase price), the tax valuations are prepared on
a legal entity or tax-jurisdictional basis. Transfer
pricing should be embedded within the tax
valuations even though it may be less relevant to
financial reporting valuations performed on a
consolidated or reporting unit level. In addition, for
tax and book purposes, an economic analysis is
often used in determining an asset’s fair value
based on the expected level of income (discounted
cash flows) to be generated by that asset. The tax
cash flows relating to an asset can depend upon the
tax jurisdictions and respective tax rates applied to
intercompany transactions involving the asset.
Transfer pricing should also be considered in
measuring deferred taxes recorded in acquisition
accounting, assessing the need for a valuation
allowance, and recording any required tax reserves.
Disclosures
Companies should consider the impact that
transfer pricing may have on accounting estimates
and assertions that may warrant disclosure in the
financial statements. This becomes increasingly
important due to disclosures recommended by the
OECD in the CBCR template (see our comments
above).
Income tax footnote disclosures might include a
discussion of a transfer pricing strategy that serves
as objective positive evidence in support of the
realisation of a company’s deferred tax assets.
Increases and decreases in the tabular
reconciliation of unrecognised tax benefits related
to transfer pricing uncertainties should be reported
exclusive of corresponding benefits in other
jurisdictions. Early warning disclosure may be
warranted for possible near-term changes in
uncertain transfer pricing positions.
U.S. Securities and Exchange Commission (SEC)
registrants are required to discuss their current
financial condition and expected changes in
Management’s Discussion & Analysis of Financial
Condition and Results of Operations (MD&A).
Consideration should be given to the impact of
transfer pricing in these discussions. That may
include, for example, risks and uncertainties
associated with transfer pricing policies that could
impact liquidity or capital resources. Potentially
significant consequences of legislative or regulatory
proposals may be discussed. In some
circumstances, material terms of APAs may
warrant disclosure.
Global tax accounting services newsletter
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In this issue
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Accounting and
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tax law changes
Tax accounting refresher
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Contacts
For more information on the topics discussed
in this newsletter or for other tax accounting
questions, including how to obtain copies of
the PwC publications referenced, contact your
local PwC engagement team or your Tax
Accounting Services network member listed
here.
Global and regional tax accounting leaders
Global and United Kingdom
Asia Pacific
Andrew Wiggins
Global and UK Tax Accounting
Services Leader
+44 (0) 121 232 2065
[email protected]
Terry SY Tam
Asia Pacific Tax Accounting
Services Leader
+86 (21) 2323 1555
[email protected]
EMEA
Latin America
Kenneth Shives
EMEA Tax Accounting
Services Leader
+32 (2) 710 4812
[email protected]
Marjorie Dhunjishah
Latin America Tax Accounting
Services Leader
+1 (703) 918 3608
[email protected]
Continued
Global tax accounting services newsletter
Introduction
In this issue
Home Subscription
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Accounting and
reporting updates
Recent and upcoming major
tax law changes
Tax accounting refresher
Contacts and primary authors
Contacts
Tax accounting leaders in major countries
Country
Name
Telephone
Email
Australia
Ronen Vexler
+61 (2) 8266 0320
[email protected]
Belgium
Koen De Grave
+32 (3) 259 3184
[email protected]
Brazil
Manuel Marinho
+55 (11) 3674 3404
[email protected]
Canada
Spence McDonnell
+1 (416) 869 2328
[email protected]
China
Terry SY Tam
+86 (21) 2323 1555
[email protected]
France
Thierry Morgant
+33 (1) 56 57 49 88
[email protected]
Germany
Heiko Schäfer
+49 (69) 9585 6227
[email protected]
Hungary
David Williams
+36 (1) 461 9354
[email protected]
Japan
Masanori Kato
+81 (3) 5251 2536
[email protected]
Mexico
Fausto Cantu
+52 (81) 8152 2052
[email protected]
Netherlands
Jurriaan Weerman
+31 (0) 887 925 086
[email protected]
United Kingdom
Andrew Wiggins
+44 (0) 121 232 2065
[email protected]
United States
David Wiseman
+1 (617) 530 7274
[email protected]
Global tax accounting services newsletter
Introduction
In this issue
Home Subscription
Home
Accounting and
reporting updates
Recent and upcoming major
tax law changes
Primary authors
Andrew Wiggins
Steven Schaefer
Global and UK Tax Accounting
Services Leader
+44 (0) 121 232 2065
[email protected]
National Professional Services
Group Partner
+1 (973) 236 7064
[email protected]
Katya Umanskaya
Global and US Tax Accounting
Services Director
+1 (312) 298 3013
[email protected]
Tax accounting refresher
Contacts and primary authors
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