COUNTRY REPORTS. Whereas the United States of America and the Kingdom of the Netherlands, in respect of Curaçao, desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate; Whereas the laws of the United States of America and Curaçao, are expected to require the Reporting Entity of an MNE Group to annually file a CbC Report; Whereas the CbC Report is one element of a standardized approach to transfer pricing documentation which is intended to provide tax administrations with relevant and reliable information to perform an efficient and robust transfer pricing risk assessment analysis;
COUNTRY REPORTS. Whereas the Government of the United States of America and the Government of Gibraltar desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate; Whereas the laws of the United States of America and Gibraltar require the Reporting Entity of an MNE Group to annually file a CbC Report; Whereas the CbC Report is one element of a standardized approach to transfer pricing documentation which is intended to provide tax administrations with relevant and reliable information to perform an efficient and robust transfer pricing risk assessment analysis;
COUNTRY REPORTS. Whereas the Government of the United States of America and the Government of the Federal Republic of Germany concluded an Agreement on the Exchange of Country-by-Country (CbC) Reports at Berlin on August 14, 2020 (the “Agreement”);
COUNTRY REPORTS. Whereas, the Government of the United States of America and the Government of the Republic of South Africa desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate;
COUNTRY REPORTS. Whereas the Government of the United States of America and the Government of the Republic of Singapore (“Singapore”) desire to increase international tax transparency and improve access of their respective tax authorities to information regarding the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which multinational enterprise groups (“MNE Groups”) operate through the automatic exchange of annual country-by-country reports (“CbC Reports”), with a view to assessing high-level transfer pricing risks and other base erosion and profit shifting related risks, as well as for economic and statistical analysis, where appropriate; Whereas the laws of the United States of America and Singapore require the Reporting Entity of an MNE Group to annually file a CbC Report; Whereas the CbC Report is one element of a standardized approach to transfer pricing documentation which is intended to provide tax administrations with relevant and reliable information to perform an efficient and robust transfer pricing risk assessment analysis;
COUNTRY REPORTS. Lo scopo dei country reports presentati in questo capitolo è quello di indentificare ed analizzare gli ostacoli al libero movimento dei lavoratori e dei cittadini, che potrebbero derivare dai differenti sistemi di sicurezza sociale dei paesi partner. Per identificare tali ostacoli sono stati presi in considerazione, in particolare, due aspetti: i) gli ostacoli di natura procedurale che limitano, nonostante il Regolamento europeo 883/2004, la portabilità delle prestazioni previdenziali da un paese all’altro; ii) le caratteristiche dei sistemi di sicurezza sociale, in termini di requisiti di assicurazione e di raggiungimento dei diritti alle prestazioni, che incidono sulla mobilità stessa dei lavoratori. Ogni report è stato curato dai rispettivi partner sulla base delle informazioni già fornite nei documenti sullo “Stato dell’Arte” riferito a ciascun sistema di sicurezza sociale e nelle “Griglie di Autovalutazione” sull’effettivo recepimento dei Regolamenti europei da parte di ciascun Paese.
