The increased global enforcement and BEPS CbyC reporting is expected to have the largest impact, by increasing the risk of transfer pricing examination and double taxation.
In the aftermath of BEPS and the implementation of CbyC reporting, many more companies will likely find benchmark APAs to be a viable option.
Although the paradigm is to have the ultimate group parent file the CbyC report, the report will be made available to other jurisdictions where the group operates under automatic exchange of information agreements.
Let's imagine you are an examiner in Country X, and have received a copy of Company A's CbyC report.
As a tax director whose workdays aren't getting any shorter or simpler, it is tempting to delegate the CbyC report and similar data mining and compliance exercises to others, including to technology.
The CbyC report focuses on the tax information of tax-paying enterprises (including taxable permanent establishments) within a given jurisdiction.
The crew will include Martin's daughter Abby, CBYC
members Colin Parsons, Elsa Stewart and Rowley MacLarg and Annie's doctor Paul Morrison.
In the Senior Silver Fleet there were also some strong performances by the CBYC
sailors with Rhys Williams finishing 12th, Mila Monaghan 17th, Sam Kneale 29th, Felicity Allen 63rd and Alice Reynolds 69th.
1st - Harri Pain - CBYC
, 2nd - Tobias Shapton - Mumbles, 3rd and 1st Girl - Chloe Butterworth - Pwllheli SC General Handicap: 1st Youth - Josh and Jake Davies (29er) - Pwllheli SC, 1st Girls - Daneille Rowe and Rachel Tilley (29er) - Llandegfedd SC, 1st - Rowan Edwards and Daniel Blight (29er) - PDSC, 2nd Frankie Dickens (Laser Radial) - Mumbles, 3rd Aled Goddard (Laser Radial) - Bala SC Optimist Regatta Fleet: 1st and 1st Girl - Madeline Leary - Mumbles, 2nd - Rhianwen Williams - CBYC
, 3rd -Ethan Kneale - CBYC
Topper Regatta Fleet: 1st - Ed Pickett - Fishguard, 2nd - Max Falmer - Llangorse, 3rd - Theo Falmer - Llangorse, 1st Girl - Izzie Millar - Llandegfedd General Handicap Regatta fleet: 1st - Grace Barton (Tera) - Clywedog SC
There is more than pounds 1,000 in cash and prizes to be won in the 8am to 7pm competition, which costs pounds 7 to enter and is centred on CBYC
's club house.