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Global tax accounting
services newsletter
Focusing on tax
accounting issues
affecting businesses
today
October – December
2014
Global tax accounting services newsletter
Introduction
In this issue
Home Subscription
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
andrew.wiggins@uk.pwc.com
The Global tax accounting services newsletter is
a quarterly publication from PwC’s Global Tax
Accounting Services (TAS) 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,
the most recent International Financial
Reporting Standards (IFRS) Interpretation
Committee’s guidance on some tax-related
matters, State aid developments, and
enforcement priorities in relation to 2014 IFRS
financial statements recently released by the
European Securities and Markets Authority
(ESMA).
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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
December 2014.
Finally, we discuss key tax accounting hot topics
and year-end reminders.
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
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
The IFRS Interpretations Committee (IFRS IC) update
State aid developments
ESMA’s enforcement priorities in relation to 2014 IFRS
financial statements
Recent and upcoming major tax law changes
•
•
Notable tax rate changes
Other important tax law changes
Tax accounting refresher
•
Key tax accounting hot topics and year-end reminders
Contacts and primary authors
•
•
•
Global and regional tax accounting leaders
Tax accounting leaders in major countries
Primary authors
Global tax accounting services newsletter
Introduction
In this issue
Home Subscription
Accounting and
reporting updates
Recent and upcoming major
tax law changes
Tax accounting refresher
Contacts and primary authors
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
that will be issued to solicit broad stakeholder
input.
Overview
During its decision-making meeting on 22
October 2014, the FASB also agreed to issue an
exposure draft related to the following income
tax accounting topics:
During its meeting on 8 October 2014, the
Financial Accounting Standards Board (FASB or
Board) decided to add the following stock-based
compensation topics to its agenda as part of its
simplification initiative:


whether to require recognition of all excess
tax benefits (windfalls) and deficiencies
(shortfalls) within income tax expense and
remove the current requirement that cash
taxes payable be reduced in order to record a
windfall tax benefit.
whether to eliminate the requirement to
display the gross amount of windfalls as an
operating outflow and financing inflow in
the statement of cash flows
These income tax accounting considerations will
be addressed along with certain other stockbased compensation topics that were also added
to the agenda. The Board’s deliberation of these
topics is expected to result in an exposure draft

elimination of the exception for recognising
deferred taxes on certain intercompany
transactions

classification of all deferred tax assets and
liabilities as non-current
The exposure draft is expected to be issued in
January 2015. Stakeholders will have the
opportunity to provide feedback during a 120day comment letter period.
In detail
Stock compensation
On 8 October 2014, the FASB voted to include
two income tax accounting topics to the stockbased compensation project and encouraged the
FASB staff to continue researching the
possibility of entirely eliminating the intraperiod tax allocation rules as a separate project.
Continued
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The Board agreed to address the possible
recognition of all windfalls and shortfalls within
income tax expense. As a reminder, windfalls
occur when a stock-based award results in a
larger tax deduction than the amount of
compensation recorded for book purposes,
whereas shortfalls occur when the award results
in zero or less of a tax deduction than the related
book charge.
That proposed treatment would replace the
current guidance that allocates tax effects
between equity and income tax expense.
The FASB staff presented two alternatives to the
Board:

alternative A: Record all windfalls and
shortfalls in income tax expense

alternative B: Record all windfalls and
shortfalls in equity
The FASB staff noted that either alternative
would eliminate the necessity of maintaining a
windfall ‘pool’ and the potential asymmetry in
the classification of tax effects. Both alternatives
included the staff’s recommendation to remove
the current requirement that cash taxes payable
must be reduced in order to record a windfall.
The staff had also considered potential
convergence with IFRS but concluded that
convergence would not result in simplification.
Ultimately, the Board voted to include only
alternative A in the stock-based compensation
project.
Additionally, the Board agreed with the staff’s
recommendation to include the possible
elimination of the current requirement to
display the gross amount of windfall as an
operating outflow and financing inflow in the
cash flow statement. The FASB staff noted that
this presentation does not reflect actual cash
flows, and represents the only exception from
single-line presentation of taxes within operating
cash flows.

The exposure draft is expected to be released in
January 2015.
One of the changes to be reflected in the
exposure draft would require recognition of the
current and deferred income tax consequences
of an intra-entity asset transfer when the
transfer occurs. This would replace the current
exception that requires that both the buyer and
the seller in a consolidated reporting group defer
the income tax consequences of intra-entity
asset transfers.
The FASB staff presented two alternatives to the
Board:

alternative A: Retain the exception and
provide guidance about applying the
exception to intangible assets

alternative B: Eliminate the exception
Exposure draft
On 22 October 2014, the FASB also agreed to
issue an exposure draft related to the following
two income tax accounting topics:

classification of all deferred tax assets and
liabilities as non-current
elimination of the exception for recognising
deferred taxes on certain intercompany
transactions
Continued
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Contacts and primary authors
Accounting and reporting updates
The Board noted that alternative B should
reduce complexity for users, preparers,
regulators, and auditors of financial statements.
Alternative B would also allow convergence with
IFRS and result in accounting that will be more
transparent (i.e., tax provision would reflect
current tax consequences of intercompany
transactions) and in many cases closer to
reflecting tax cash flows.
Ultimately, the Board voted to include
alternative B in the exposure draft.
The Board also agreed to the staff’s
recommendation to require the classification of
all deferred tax assets and liabilities as noncurrent on the balance sheet. This would replace
the current guidance, which requires deferred
taxes for each tax-paying component of an entity
to be presented as a net current asset or liability
and a net non-current asset or liability, and
eliminate the complexity around the allocation
of a valuation allowance between current and
non-current. The proposed guidance would also
converge with IFRS.
Finally, the Board voted on the staff’s
recommendations for transition methods and
effective dates. The Board agreed to a modified
retrospective transition approach (i.e.,
cumulative catch-up adjustment to opening
retained earnings in the period of adoption) for
the intercompany transactions topic and
prospective transition for the classification topic.
In the period of adoption, transition disclosures
will include: (1) the nature of and reason for the
accounting change and (2) the method of
applying the change which would include the
effects of the change on any affected financial
statement line item and per-share amounts for
the current period. In lieu of disclosing the
effects of the change on the balance sheet for the
classification topic, the Board agreed that the
disclosure would note that the presented balance
sheets are not comparable.
The changes would be effective for financial
reporting years beginning after 15 December
2016, for public companies. For private
companies, changes would be effective for
financial reporting years beginning after 15
December 2017, and interim periods in the
following year. Early adoption to the public
companies’ effective date would be permitted for
private companies. Early adoption, if chosen,
would need to be applied to both topics.
Takeaway
The steps recently taken by the FASB and the
ongoing efforts of the FASB staff may lead to
significant near-term improvements that could
reduce the complexity of accounting for income
taxes. At present, there are two projects that
address the simplification of income tax
accounting: the income tax project and the
stock-based compensation project. Income taxes
are also included in the Disclosure Framework
project and the FASB staff continue to study
intra-period tax allocation.
Organisations should be giving attention to the
implications of potential near-term changes in
these tax accounting areas. Consideration should
be given to responding to the exposure draft
once it is issued.
There are also likely to be further developments
as the FASB works through the tax accounting
topics now on its agenda.
Continued
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Accounting and reporting updates
The IFRS IC update
Overview
During the fourth quarter of 2014 the IFRS IC
considered the following two issues:


measurement of current income tax on
uncertain tax positions (UTPs)
selection of the applicable tax rate for the
measurement of deferred tax relating to an
investment in an associate in a multi-tax rate
jurisdiction
The IFRS IC discussed the UTP issues earlier in
2014 (see the Q1 and Q3 2014 newsletters) and
noted that one of the principal issues with respect
to UTPs is how to measure related assets and
liabilities. It tentatively decided to proceed with
developing guidance for the measurement of UTPs.
In addressing the issue of the applicable tax rate for
the measurement of deferred tax relating to an
investment in an associate in a multi-tax rate
jurisdiction, the IFRS IC noted that IAS 12 contains
sufficient guidance on this matter and decided not
to add this issue to its agenda.
Measurement of current income tax on
uncertain tax position
As mentioned above, the IFRS IC tentatively
decided to proceed with the project on the
measurement of UTPs, subject to further analysis
and deliberations.
During its November 2014 meeting, the IFRS IC
discussed:

the scope of the project

the unit of account for measurement of UTPs

a possible approach for the measurement
method(s)
Scope
The IFRS IC tentatively agreed that all income tax
positions should be included within the scope of
this project. It thought that attempting to limit the
scope to specific situations, for example, when an
entity has unresolved disputes with a tax authority,
would lead to an arbitrary rule.
The IFRS IC also noted that paragraph 14 of IAS 12
and the objective of IAS 12 refer to the ‘probable’
recognition threshold, although IAS 12 does not
explicitly set the threshold of recognition for a
current tax asset or liability. It also noted that the
current Conceptual Framework for Financial
Reporting also refers to a probable recognition
threshold. As noted in the final decision on the
issue of recognition of current income tax on UTPs
in July 2014, it is IAS 12, not IAS 37 Provisions,
Contingent Liabilities and Contingent Assets, that
provides the relevant guidance on recognition.
The IFRS IC observed that setting a scope to
specific situations is not necessary if it develops
guidance that would require an entity to recognise
a current tax asset or liability only if it is probable
that it will pay the amount to, or recover the
amount from, a tax authority.
As a result, the IFRS IC tentatively agreed that the
proposed guidance should require an entity to
recognise a current tax asset or liability only if it is
probable that it will pay the amount to, or recover
the amount from, a tax authority.
Unit of account
The IFRS IC observed that an entity should make a
judgement about the unit of account that provides
relevant information for each UTP. For example, if
a decision on a specific UTP is expected to affect, or
be affected by, other UTPs, it noted that those
UTPs should be accounted for as a single unit of
account.
Continued
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Approach for measurement
The IFRS IC observed that an entity should
estimate the amount expected to be paid to (or
recovered from) the taxation authorities by using
either the most likely amount or the expected
value, depending on which method provides a
better estimate. This is because this approach
would provide useful information to predict future
cash flows for each case. It also noted that this
approach is similar to the measurement of an
amount of variable consideration in IFRS 15. The
IFRS IC decided not to propose a more-likely-thannot measurement threshold, noting that IFRS does
not refer to a more-likely-than-not amount and
that both IFRS 15 and IAS 37 refer to the expected
value and the most likely amount.
As mentioned in the Q3 2014 newsletter, the IFRS
IC had tentatively decided that the proposed
guidance should clarify 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).
contact the staff of the FASB, to discuss its
experience with developing guidance on this
subject.
Selection of the applicable tax rate for
measurement of deferred tax relating to
investment in associate
As mentioned above, the IFRS IC received a
request to clarify the selection of the applicable tax
rate for the measurement of deferred tax relating to
an investment in an associate in a multi-tax rate
jurisdiction.
The IFRS IC was asked how the tax rate should be
selected when local tax legislation prescribes
different tax rates for different manners of recovery
(for example, dividends, sale, and liquidation) in
the following situation:
The carrying amount of an investment in an
associate could be recovered by:

receiving dividends (or some other distribution
of profit)

sale to a third party, or
Form of guidance

The IFRS IC tentatively decided to develop a draft
Interpretation, reflecting the above tentative
decisions.
receiving residual assets upon liquidation of
the associate
An investor normally considers all of these means
of recovery.
One part of the temporary difference will be
received as dividends during the holding period,
and another part will be recovered upon sale or
liquidation.
The IFRS IC noted that paragraph 51A of IAS 12
states that an entity measures deferred tax
liabilities and deferred tax assets using the tax rate
and the tax base that are consistent with the
expected manner of recovery or settlement.
If one part of the temporary difference is expected
to be received as dividends, and another part is
expected to be recovered upon sale or liquidation
(for example, an investor has a plan to sell the
investment later and expects to receive dividends
until the sale of the investment) different tax rates
would be applied to the different parts of the
temporary difference to be consistent with the
expected manner of recovery.
The IFRS IC observed that it had received no
evidence of diversity in the application of IAS 12
and that the Standard contains sufficient guidance
to address the matters raised. Accordingly, the
IFRS IC determined that neither an Interpretation
of, nor an amendment to, IAS 12 was necessary and
decided not to add this issue to its agenda.
The staff will present the draft Interpretation at a
future meeting. The IFRS IC also asked the staff to
Continued
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Accounting and reporting updates
State aid developments
Overview
At the beginning of 2014, the European
Commission announced a new focus on ‘fiscal’
State aid. This focus was in part triggered by the
unfolding Organisation for Economic Co-operation
and Development’s (OECD)/G20’s Base Erosion
and Profit Shifting (BEPS) Action Plan as well as
the European Union’s (EU) own agenda to crack
down on what may be viewed as unfair incentives
or subsidies which contravene EU-wide fair trade
or competition principles.
This has resulted in the opening of a series of
investigations into specific tax rulings and tax
regimes, including the following:

examination of the Gibraltar tax ruling
practice, which dates from 2010

examination of transfer pricing agreements in
Ireland, Luxembourg, and Netherlands
The European Commission also announced that an
administrative interpretation of the Spanish
tax authorities issued in March 2012, which
allowed companies to amortise the financial
goodwill on indirect shareholdings, is incompatible
with EU State aid rules. However the General Court
of the EU recently overturned this decision on the
basis that the approach to selectivity (see further
comments on the point of selectivity below)
adopted by the Commission was wrong. The
European Commission may now appeal to the
Court of Justice of the EU.
In detail
What is ‘fiscal’ State aid?
EU State aid rules are relevant for undertakings
with business activities in the Member States of the
EU and the three countries of the European
Economic Area (EEA, i.e., the EU, Iceland,
Liechtenstein, and Norway). The term
‘undertaking’ has been widely construed by the
courts but would include activities carried on by
partnerships and companies, including activities
carried on through a permanent establishment.
These States are prohibited from providing certain
forms of State aid to undertakings without prior
authorisation of the European Commission (or the
European Free Trade Association (EFTA)
Surveillance Authority with respect to Iceland,
Liechtenstein, and Norway). This prohibition is
part of European competition law, and is intended
to safeguard fair competition within the EU/EEA.
The legal basis for the State aid ban is in the Treaty
on the Functioning of the European Union (TFEU)
or for Iceland, Liechtenstein, and Norway in the
EEA Agreement.
The most straightforward example of State aid is a
subsidy provided directly to a certain undertaking.
However, State aid can also consist of a reduction
of taxes otherwise due (e.g., a tax exemption), as
this provides an advantage to certain undertakings
(i.e., the tax rulings or regimes are determined to
be selective). This is referred to as ‘fiscal’ State aid.
Forms of fiscal State aid
Broadly speaking, fiscal State aid comes in two
forms:

a tax measure or regime that provides a
selective advantage

an individual concession granted to a taxpayer
(e.g., through the use of a tax ruling or via a
settlement)
Continued
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Unlawful State aid
Under certain circumstances aid granted by EU or
EEA Member States can be compatible with EU
Law. It is up to the European Commission to
determine (subject to appeal) whether aid is
compatible with the EU’s internal market. Aid
granted without prior authorisation of the
European Commission or the EFTA Surveillance
Authority, is assumed to be unlawful until proven
otherwise.
If the European Commission or the EFTA
Surveillance Authority ultimately conclude that the
tax benefit in question was more generous than
either the local law allowed, or that the local law
itself gave an unjustifiable selective tax advantage,
then the Commission may be obliged to order the
State to recover the unlawful tax benefit from the
taxpayer with compound interest for up to ten
years prior to the opening of the investigation.
Existing aid (broadly, aid schemes and individual
aid which were in place before the relevant
Member State signed onto EU/EEA Treaties) is not
subject to recovery. The European Commission and
the EFTA Surveillance Authority monitor such aid
and may order that the aid be removed
prospectively.
Quantification of State aid
The aid subject to recovery should be quantified by
comparing the tax, which should ‘normally’ have
been paid—i.e., without application of the selective
tax measure—with the tax that has in fact been
paid.
Takeaway
Organisations will need to monitor State aid
developments and investigations and consider
possible financial implications whenever a tax
ruling, tax settlement, or even tax regime may be
considered State aid. The accounting consequences
of such investigations, based on available
information, are likely to be in the scope of ASC740
Income Taxes and IAS 12, Income Taxes.
Organisations should assess the potential effect on
existing uncertain income tax positions, as well as
amounts owed for previously considered closed
periods and possible refund claims or positions to
be taken in the future.
State aid should also be an important consideration
when establishing any new tax position with the tax
authorities, whether in relation to a tax ruling, tax
settlement, or the application of a specific tax
regime. Any measure in an EU or EEA Member
State, be it a tax rule, regime, system, assessment,
agreement, or ruling should be considered from a
State aid perspective.
Organisations may need to seek expert support in
assessing risks or uncertainty from appropriate
legal counsel. Expert analysis should address the
company’s position in the context of the relevant
accounting standard, such as the ‘more likely than
not’ recognition threshold of ASC 740.
Organisations will also need to document
management’s view and associated controls, and
consider the relevant disclosure requirements.
Continued
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ESMA’s enforcement priorities in
relation to 2014 IFRS financial
statements
1.
Overview
2. financial reporting by entities which have
joint arrangements and related disclosures
ESMA is an independent EU Authority, whose
predominant role is to serve as the EU’s
securities market regulator. One of ESMA’s
areas of responsibility is to promote the effective
and consistent application of the European
Securities and Markets legislation with respect
to financial reporting.
On 28 October 2014, ESMA issued its public
statement on the European common
enforcement priorities for 2014 IFRS financial
statements. These priorities identify topics that
ESMA, together with European national
enforcers, see as a key focus of their
examinations of listed companies’ financial
statements.
In detail
Based on the public statement ESMA’s
enforcement priorities for FY 2014 are focused
on the following topics:
preparation and presentation of
consolidated financial statements and
related disclosures
3. recognition and measurement of deferred
tax assets
These topics were highlighted as they related to
either:

significant changes to accounting practices
as a result of new standards such as IFRS 10,
11, and 12 or

challenges to issuers as a result of the
current economic environment, notably
when forecasting future taxable profits in
periods of low economic growth (IAS 12)
With respect to income taxes (IAS 12), ESMA
noted that particular attention should be paid to
the recognition of deferred tax assets coming
from the carry-forward of unused tax losses, to
the assessment whether future taxable profits
exist, and to the need for disclosing judgments
made when recognising deferred tax assets.
When the utilisation of the deferred tax asset is
dependent on future taxable profits or when the
entity has suffered a loss in either the current or
preceding period in the tax jurisdiction to which
the deferred tax asset relates, paragraph 82 of
IAS 12 requires the disclosure of the amount of a
deferred tax asset and the nature of the evidence
supporting its recognition.
In this respect ESMA expects issuers to disclose
specific significant assumptions made in their
business plans, as losses can be carried forward
over very long periods, and the business plans
that support the existence of future taxable
profits are based on assumptions that are often
highly judgmental.
When amounts are material, issuers should
consider separate disclosures based on the
characteristics of the tax losses, e.g., considering
different time limits during which tax losses
must be utilised.
Continued
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ESMA believes that it is particularly relevant to
disclose the following information:

the period used for the assessment of the
recovery of a deferred tax asset

the judgments made when determining it

the amount of tax losses carried forward for
which deferred tax assets were recognised
compared to the total tax losses carried
forward that are available for each material
tax group or entity.
Finally, ESMA noted that the IFRS IC recently
discussed the question of recognition and
measurement of income taxes in relation to
uncertain tax positions (see above). In light of
these discussions, ESMA expects issuers to
disclose their accounting policy related to
material uncertain tax positions in accordance
with paragraphs 117 and 122 of IAS 1
Presentation of Financial Statements.
Takeaway
The public statement of ESMA clearly
demonstrates that income taxes are high on the
current agenda.
Organisations should be paying particular
attention to recognition, measurement, and
disclosure requirements for deferred tax assets
on carry-forward tax losses.
Companies should also keep a close watch on the
IFRS IC developments on uncertain tax
positions and consider the follow on
consequences for disclosures.
Contacts and primary authors
Global tax accounting services newsletter
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Recent and upcoming major
tax law changes
Tax accounting refresher
Contacts and primary authors
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. Any significant income
tax law developments that occur in December
2014 and not covered by this newsletter will be
highlighted in a separate tax law changes alert
in January 2015.
Notable enacted tax rate changes
Country
Prior rate
New rate
Portugal (CIT)
23%
21%1
Spain (CIT)
30%
28%/25%2
Thailand (CIT for the 2015
year)
30%
20%3
1 This
change was substantively enacted on 31 October 2014, and is effective from 1 January 2015.
The corporate income tax rate in Spain was reduced from 30% to 28% in 2015 and to 25% in 2016 (30% rate would continue to apply
to financial institutions). This change was enacted on 28 November 2014.
3 The statutory CIT rate in Thailand has historically been 30%. The CIT rate was reduced to 20% for 2013 and 2014, and the 20% rate
has now been extended to 2015. This change was enacted on 10 November 2014.
2
Continued
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Other important tax law changes
Click each circle to review
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Recent and upcoming major tax law changes
Australia
extend roll overs (that would generally allow
for a deferral of tax) to circumstances where
the relevant shares or units are held as revenue
assets or trading stock) were removed.

An anti-avoidance rule has been introduced to
target certain ‘back-to-back’ loan arrangements
that aim to avoid application of withholding tax
and thin capitalisation rules.

Access to the managed investment trust
withholding regime is allowed for foreign
pension funds.


An exemption from tax on income derived by
entities engaged in US Force Posture Initiatives
is now available.
The ‘regulated foreign financial institution
exception’ in the foreign accrual property
income (FAPI) regime has been amended to
ensure the exception does not apply to nonfinancial institutions.

It has been clarified that the anti-avoidance
rule in the FAPI regime will apply to certain tax
planning arrangements referred to as
‘insurance swaps.’
During the fourth quarter of 2014, the following
tax measures were enacted in Australia:




Amendments were made to the thin
capitalisation rules (1) to reduce the deductible
debt limits from a debt-to-equity ratio of 3:1 to
1.5:1, (2) to increase the de minimis threshold
exemption from AUD 250,000 to AUD
2,000,000, and (3) make the worldwide
leverage ratio test available to Australian
inbound and outbound groups.
The participation exemption for dividends
received from foreign companies on shares that
qualify as debt interests under the Australian
debt/equity rules was removed.
A new integrity measure with respect to the
non-resident capital gains tax (CGT) provisions
was introduced. Broadly, transactions between
group members are now ignored when their
effect is to create or duplicate an asset that is
not ‘Taxable Australian Property’ in order to
potentially avoid Australian CGT.
Tax impediments to certain business
restructures (broadly, the changes would
The Australian Taxation Office (ATO) also provided
long-awaited draft guidance on the application
of the equity over-ride rule. This rule
reclassifies a debt interest issued by a company to a
‘connected entity’ as an equity interest and treats
distributions on that interest as dividends.
Canada
During the fourth quarter of 2014, certain 2014
budget proposals (see the Q1 2014 newsletter)
were substantively enacted, including the
following:

In addition, the following measures were
substantively enacted:

amendments to the foreign affiliate dumping
rules (these rules broadly apply when a foreign
parent company uses its Canadian affiliate to
invest in another foreign affiliate)

amendments to taxation of Canadian
corporations with foreign affiliates
A domestic anti-avoidance rule has been
introduced to target ‘double tax treaty
shopping.’
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

amendments to the application of the ‘exempt
surplus’ (i.e., active business income earned in
a treaty country) rules to certain Australian
resident trusts in which a controlled foreign
affiliate of a Canadian corporation has a
beneficial interest
amendments to trust loss restriction event
rules (these rules broadly apply when there is a
change in the majority-interest beneficiary of
the trust)
Germany
During the fourth quarter of 2014, the relevant
committees of the German Bundesrat (the states
council of the German parliament) issued a joint
recommendation to include certain tax
provisions in a draft bill that would amend the
General Tax Code as it pertains to the EU Customs
Codex and other tax provisions (ZollkodexAnpG).
The proposed amendments include:

Colombia
During the fourth quarter of 2014, the Colombian
government introduced the following tax
reform proposals:

A temporary net wealth tax would be assessed
on net equity on domestic and foreign legal
entities.

The rate of the income tax on equality (CREE
for its Spanish acronym) would be kept at 9%

non-deductibility of business expenses when
there is no corresponding income inclusion,
and shut down of certain ‘double-dip’
structures (amendments reflecting the OECD’s
base erosion and profit shifting initiative, or
BEPS)

removal of the 95% participation exemption for
capital gains on portfolio shares (defined as
less than 10% ownership) in a German
corporation.

broadening the intra-group exception in the
German loss forfeiture rules

‘clarification’ of the attribution rules for the
events triggering the imposition of the real
A CREE surcharge would be applied until 2018.
estate transfer tax (RETT) for indirect transfers
of German real estate owning partnerships

limitation of the allowable consideration (other
than shares, e.g., cash or loan receivables) in a
tax-free in-kind contribution under the
Reorganisation Tax Act. Currently, an in-kind
contribution (including share-for-share
exchanges) may be treated tax-free although
the transferor receives additional consideration
besides shares/interest of the recipient entity
(e.g., cash or loan receivables, commonly
known as boot) up to the net tax basis of the
contributed assets and liabilities.
Hungary
During the fourth quarter of 2014, changes to tax
loss carry-forward rules were enacted in Hungary.
In particular, tax losses incurred after 2015 would
be available for utilisation within five years; losses
incurred before 2015 would be available for
utilisation up to 31 December 2025; and rules on
transferring carried-forward tax losses incurred in
relation to reorganisations or takeovers would be
tightened.
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Ireland
Italy
During the fourth quarter of 2014, the Minister for
Finance of Ireland announced the Irish Budget
2015, that included the following proposed
measures:
During the fourth quarter of 2014, the following
measures were proposed in Italy:

reaffirmed commitment to maintaining
Ireland’s 12.5% corporation tax rate for active
trading income

changes to corporate tax residence rules
to ensure that Irish incorporated companies
can only be considered non-Irish tax resident
under the terms of a double tax treaty

introduction of a new ‘Knowledge Development
Box’ regime, and enhancement of the existing
intangible property (IP) regime for
expenditures on intangible assets

enhancements to Ireland’s existing R&D tax
credit regime

The 2014 financial year IRAP rate decrease
would be repealed.

Certain employment costs would be fully
deductible for IRAP purposes.

A Patent Box regime would be introduced.
The regime would grant an exemption for
corporate and regional tax purposes in respect
of income sourced from intangible assets. In
the first two years (2015 and 2016) the
exemption would be 30% and 40% of the
relevant income; thereafter it would be 50%.
Taxpayers would be required to enter into an
Advanced Pricing Agreement (APA) with the
Italian Revenue Agency to benefit from the
regime.
Luxembourg
During the fourth quarter of 2014, it was proposed
that starting in 2015 a minimum corporate income
tax of EUR 3,000 (EUR 3,210 with the solidarity
surtax) would be applicable to all Luxembourg
entities that own fixed assets, transferable
securities and cash at bank exceeding 90% of their
total assets and EUR 350,000.
Malta
During the fourth quarter of 2014, Malta enacted
an investment tax credit for tangible/intangible
asset investment or new job creation. This tax
credit is effective from 1 July 2014.
Mexico
During the fourth quarter of 2014, the Mexican Tax
Authorities have published Form 76,
Information Return Regarding Relevant
Transactions requiring the disclosure of certain
information, including financing transactions
relating to derivatives, transfer pricing, changes in
the capital structure, or tax residency,
restructurings and reorganisations.
The form must be filed electronically within 30
working days after the occurrence of a relevant
transaction. Relevant transactions that occurred
during the 2014 calendar year must be reported on
Form 76 by 31 January 2015.
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Panama
Portugal
Russia
During the fourth quarter of 2014, the Panamanian
government enacted Law 25, granting an amnesty
for tax payments for liabilities accrued before 30
September 2014. Taxpayers that take advantage of
the amnesty will not be subject to surcharges,
interest, or penalties on outstanding tax liabilities.
The deadline to pay tax existing liabilities is 31
December 2014.
During the fourth quarter of 2014, the Portuguese
Government substantially enacted certain
measures presented in its State Budget for 2015
including the following:
During the fourth quarter of 2014, Russia
eliminated the 30% penalty tax rate on
dividends payable on the shares of Russian
issuers recorded through depositary programs and
other accounts of foreign intermediaries. This rate
previously applied when information about the
beneficial owners of dividends was not disclosed in
due course to a Russian tax agent. With the change,
effective on 1 January 2015 the maximum Russian
withholding income tax rate on dividends will be
15%.
Poland
During the fourth quarter of 2014, the following
tax measures covered in the Q3 2014
newsletter were enacted in Poland:

amendments to the thin capitalisation rules
that are effective January 2015

introduction of controlled foreign company
(CFC) provisions, expected in January 2016
During the fourth quarter of 2014 the government
also drafted legislation for tax anti-avoidance rules.
These rules are expected to take effect in January
2016.

The standard corporate income tax rate will be
reduced from 23% to 21%.

Dividends and profits received from entities in
which they are treated as tax-deductible
expenses will no longer be able to benefit from
the participation exemption regime. This would
apply even if the dividends were paid by EU
subsidiaries.
The Portuguese government has also approved the
new Investment Tax Code, which aims to reinforce
the existing investment tax benefits and adapt
them to the new EU State aid framework.
The government also discussed a comprehensive
Green Taxation reform package that includes the
extension of the tax deductibility of provisions
made for environmental clean-up costs to all
industries (currently available only to extractive
and waste management industries).
During the fourth quarter of 2014, the lower
chamber of the Russian Parliament passed a new
‘anti-offshore’ law. The law’s main purpose is to
prevent tax avoidance by Russian tax residents
through the use of tax havens and low-tax
jurisdictions. However, it also includes measures
that affect foreign investors owning equities in
Russian entities or receiving income from Russian
entities.
The key developments in the ‘anti-offshore’ law
include the introduction of:

a beneficial ownership concept for the purposes
of applying double tax treaty (DTT) benefits
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
a tax on ‘indirect’ sales of immovable property
in Russia


a tax residency concept for legal entities, based
on place of management
Thailand

a CFC regime.
The law requires approval by the upper chamber of
the Parliament and the president. It is expected to
be effective from 1 January 2015.
Spain
During the fourth quarter of 2014, a number of tax
measures were enacted in Spain, including the
following:

Losses associated with tangible and intangible
assets on intra-group transactions are now
available for deferral.

The offset of tax losses is now limited to 70%
of taxable income.

Impairment losses in relation to tangible
assets and investment property are no longer
tax deductible.
New tax depreciation rates have been
implemented.
proposed by the OECD. The modified nexus
approach requires the tax benefits of IP
regimes to be connected directly to research
and development (R&D) expenditures. The
joint proposal amends these rules to address
concerns expressed by some countries and
seeks to tackle outstanding issues related to
qualifying expenditures, grandfathering,
transitional arrangements, and tracking
qualifying R&D expenditures.
As mentioned above, during the fourth quarter of
2014, Thailand enacted the reduction of its
corporate income tax rate for the 2015 year from
30% to 20%. Without further action the rate will
revert to 30% in 2016.
Given that Thailand is running a substantial budget
deficit, and the government has announced
significant new infrastructure spending programs,
further rate cut extensions are uncertain.

The definition of qualifying expenditures would
exclude related-party outsourcing and
acquisition costs. However, to reduce the
negative impact of this exclusion, companies
may increase their qualifying expenditures by
30%, subject to a cap based on actual
expenditures.

The proposal’s grandfathering arrangements
would allow companies that enter into IP
arrangements before June 2016 to take
advantage of existing patent box regimes for
existing patents/products until June 2021. The
new rules would apply to IP regimes entered
into in and after June 2016.
United Kingdom
During the fourth quarter of 2014, the UK and
German governments developed a joint proposal
to advance negotiations on new rules for
preferential IP regimes within the G20/OECD
BEPS project and presented it at the OECD Forum
on Harmful Tax Practices (FHTP) in November
2014. The key points of the proposal are as follows:

The proposal is intended to bridge the gaps
between OECD and G20 member countries on
the application of the modified nexus approach
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In addition, the UK government announced the
following key proposals (expected to apply from
1 April 2015):
The UK government also announced steps to
implement the OECD model for country by country
reporting and published a consultation paper on
the implementation of the proposed rules
governing hybrid mismatch arrangements, aimed
at preventing tax relief for payments where the
recipient is not taxed.

A 25% Diverted Profits Tax (targeting
‘artificially diverted profits’) would be
introduced.

The R&D expenditure credit would increase
from 10% to 11%.
United States

The amount of a bank’s annual profit that can
be offset by carried-forward losses would be
restricted to 50%.
During the fourth quarter of 2014, the Senate
voted to pass the Tax Increase Prevention
Act of 2014, providing for a one-year retroactive
extension of business and individual tax provisions
that expired at the end of 2013.
Key business provisions that would be renewed
through 31 December 2014, include the research
credit, 50% bonus depreciation, look-through
treatment for CFCs, and a Subpart F exception for
active financing income. The tax extenders package
does not include any revenue offsets.
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In this section we discuss key year-end
reminders in relation to uncertain tax
positions, valuation allowances and
disclosures. These areas continued to be
areas of focus by regulators in the US and
Europe in the 2014 calendar year.
Key tax accounting hot topics and
year-end reminders
1. Uncertain tax positions
Under US GAAP, the assessment of a UTP is a
continuous process that does not end with the
initial determination of a position’s sustainability.
At each balance sheet date, unresolved positions
must be reassessed based upon new information.
ASC740 requires that changes in the expected
outcome of a UTP be based on new information,
and not on a mere re-evaluation of existing
information.
Under IFRS, accounting for UTPs is not specifically
addressed. Organisations should account for tax
consequences of events following the manner in
which they expect the tax position to be resolved
with the tax authorities at the balance sheet date.
However, more guidance is expected to be issued
on this subject once the IFRS IC completes its
project on the measurement of UTPs (see the IFRS
IC update above).
Organisations should consider the following
reminders with respect to UTPs as part of their
year-end process:
US GAAP reminders

New information can relate to developments in
case law, changes in tax law, new regulations
issued by taxing authorities, interactions with
the taxing authorities, or other developments.
Such developments could potentially change
the estimate of the amount that is expected to
eventually be sustained or cause a position to
meet or fail to meet the recognition threshold.
While the definition of what can constitute new
information is expansive, a new or fresh
reassessment of the same information does not
constitute new information.
In assessing UTPs, an organisation is required
to recognise the benefit of a tax position in the
first interim period that one of the following
conditions is met:

The more-likely-than-not recognition
threshold is met.

The tax position is ‘effectively settled’
through examination, negotiation, or
litigation.

The statute of limitations for the relevant
taxing authority to examine and challenge
the tax has expired.
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
For a tax position to be considered effectively
settled, all three of the following conditions
must be met:

The taxing authority has completed its
expected examination procedures,
including appeals and any administrative
reviews required.

The taxpayer does not intend to appeal or
litigate any aspect of the tax position
included in the completed examination.

It is remote that the taxing authority would
examine/re-examine any aspect of the tax
position.
If the requirements of effective settlement are
met, the resulting tax benefit is required to be
reported; the application of effective
settlement criterion is not elective.

On a jurisdictional basis, ASU No. 2013-11
generally requires an unrecognised tax benefit
(UTB) to be presented in the financial
statements as a reduction to a deferred tax
asset for a net operating loss (NOL) carryforward, similar tax loss, or tax credit carryforward. This would be the case except when an
NOL carry-forward, similar tax loss, or tax
credit carry-forward is not available under the

tax laws of the applicable jurisdiction to settle
any additional income taxes resulting from the
disallowance of a tax position. In such
instances, the UTB should be recorded as a
liability and cannot be combined with the
deferred tax asset. The assessment as to
whether a deferred tax asset is available is
based on the UTB and deferred tax asset that
exist at the reporting date and should be made
assuming disallowance of the tax position at the
reporting date.

When organisations consider uncertain tax
positions in relation to each taxing authority,
the key issue is the measurement of the tax
liability. It is usually probable that an entity
will pay tax, so the recognition threshold has
been met. Organisations should calculate the
total amount of current tax they expects to pay,
taking into account all the tax uncertainties,
using either an expected value (weighted
average probability) approach or a single best
estimate of the most likely outcome.
Required disclosures related to UTPs are often
extensive and can be highly sensitive (see
below).

In later periods organisations need to decide
whether a change in the tax estimate is
justified. A change in recognition and
measurement is normally justified where
circumstances change or where new facts
clarify the probability of estimates previously
made. Such changes might be: further judicial
developments related to a specific case or to a
similar case; substantive communications from
the tax authorities; or a change in status of a
tax year (for example, moving from open to
closed in a particular jurisdiction).
IFRS reminders

When organisations consider uncertain tax
positions individually, they should first
consider whether each position taken in the tax
return is probable of being sustained on
examination by the taxing authority. They
should recognise a liability for each item that is
not probable of being sustained. The liability is
measured using either an expected value
(weighted average probability) approach or a
single best estimate of the most likely outcome.
The current tax liability is the total liability for
uncertain tax positions.
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2. Valuation allowances
US GAAP reminders
The evaluation of the need for, and amount of, a
valuation allowance for deferred tax assets is an
area that has always presented a challenge for
financial statement preparers under US GAAP. The
assessment requires significant judgment and a
thorough analysis of the totality of both positive
and negative evidence available to determine
whether all or a portion of the deferred tax asset is
more likely than not expected to be realised. In this
analysis, the accounting standard proscribes that
the weight given to each piece of positive or
negative evidence be directly related to the extent
to which that evidence can be objectively verified.
Accordingly, recently observed financial results are
given more weight than future projections (which
by their nature are often inherently subjective).

Under IFRS, deferred tax assets are recognised to
the extent that it is probable (defined as ‘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.
As companies perform their assessments, the
following reminders may be helpful:


Where local law within a jurisdiction allows for
consolidation, a valuation allowance
assessment generally should be performed at
the consolidated jurisdictional level. However,
where the local tax law does not allow for
consolidation, the valuation allowance
assessment would typically need to be
performed at the separate legal-entity level.
The accounting standard requires that all
available evidence be considered in
determining whether a valuation allowance is
needed, including events occurring subsequent
to the balance sheet date but before the
financial statements are released. However, a
valuation allowance assessment should
generally not anticipate certain fundamental
transactions such as initial public offerings,
business combinations, and financing
transactions until those transactions are
completed.
There should be clear, explainable reasons for
changes in valuation allowances. In assessing
possible changes, it is important to consider
again the basis for amounts previously
provided and how new information modifies
previous judgments. For example,
consideration should be given to whether the
results for the current year provide additional
insights as to the recoverability of deferred tax
assets or as to management’s ability to forecast
future results. The mere existence of
cumulative losses in recent years or for that
matter cumulative income in recent years is
not conclusive in and of itself of whether a
valuation allowance is or is not required.

The realisation of deferred tax assets is
dependent upon the existence of sufficient
taxable income of an appropriate character that
would allow for incremental cash tax savings.
For example, if tax losses are carried back to
prior years, freeing up tax credits (which were
originally used to reduce the tax payable)
rather than resulting in a refund, a valuation
allowance would still be necessary if there are
no additional sources of income to support the
realisation of the freed-up tax credits.
Certain tax-planning strategies may provide a
source of income for the apparent recognition
of deferred tax assets in one jurisdiction, but
not provide incremental tax savings to the
consolidated entity. In order to avoid a
valuation allowance in reliance on a taxplanning strategy, we believe that the taxplanning strategy generally must provide cash
savings to the consolidated entity.
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

Taxable temporary differences associated with
indefinite-lived assets (e.g., land, goodwill,
indefinite-lived intangibles) generally cannot
be used as a source of taxable income. Thus, a
valuation allowance on deferred tax assets may
be necessary even when an enterprise is in an
overall net deferred tax liability position.
In jurisdictions with unlimited carry-forward
periods for tax attributes (e.g., NOLs, an
alternative minimum tax (AMT) credit carryforwards, and other non-expiring loss or credit
carry-forwards), deferred tax assets may be
supported by the indefinite-lived deferred tax
liabilities.

are often critical to provide the user of the
financial statements with the insight needed to
understand management’s valuation allowance
conclusion and the key factors and evidence
utilised by management to reach it. Armed with
this information, financial statement users are
better able to assess the likelihood of the
realisation of the recorded deferred tax assets
for themselves and make more informed
conclusions about the financial condition of the
company (see also below).
The reversal of an outside basis difference in a
foreign subsidiary cannot be viewed as a source
of taxable income when the foreign earnings
are asserted to be indefinitely reinvested.
Taxable temporary differences on equity
method investments can be considered as a
source of taxable income provided there is an
appropriate expectation as to the timing and
character of reversal in relation to the deferred
tax assets.
Due to the significant judgments involved in
determining whether a deferred tax asset is
realisable, clear and transparent disclosures
IFRS reminders

Where there is a balance of favourable and
unfavourable evidence, careful consideration
needs to be given to recoverability of a deferred
tax asset (DTA) based on the entity’s
projections for taxable profits for each year
after the balance sheet date. The amount of
taxable profits considered more likely than not
for each period is assessed.

Where there are insufficient taxable temporary
differences against which a DTA can be offset,
organisations should consider the likelihood
that taxable profits will arise in the same
period(s) as the reversal of the deductible
temporary differences (or in the periods into
which a tax loss arising from the deferred tax
asset can be carried back or forward).

The assessment of taxable profits should take
account of the tax rules governing the relief of
losses, such as the type of profits permitted to
be used (that is, trading profit or capital gain).
Also organisations need to consider if the
assessment of taxable profits is restricted to the
entity with the losses, or whether group relief is
available.

In order to recognise a DTA in relation to
unused tax losses criteria in paragraph 36 of
IAS 12 need to be considered carefully when
assessing the probability that taxable profit will
be available against which these tax losses can
be utilised. Organisations need to review the
carrying amount of the resulting DTA at the
end of each reporting period in accordance
with paragraph 56 of IAS 12.

Similar to US GAAP, appropriate disclosures in
relation to the amount of a DTA and the nature
of evidence supporting the recognitions need to
be considered (see also below).
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3. Disclosures

In light of the continued focus on disclosures by
investors and regulators, companies may wish to
enhance their procedures around the identification
and development of income tax-related disclosures.
Additionally, a fresh look may be warranted to
ensure disclosures are concise and use plain
language.
When a deferred tax liability (DTL) has not
been recognised because of the exception for
indefinite reinvestment, the following
information should be disclosed:

Key reminders to consider as part of the year-end
process include the following:

the cumulative amount of each type of
temporary difference, e.g., the amount of
unremitted earnings and amount of
cumulative currency translation

the estimated amount of unrecognised DTL
or a statement that the determination of
such an estimate is not practicable
US GAAP reminders


Current deferred tax assets and liabilities
within a single tax jurisdiction should be offset
and presented as a single amount in the
balance sheet. Similarly, non-current deferred
tax assets and liabilities within a single tax
jurisdiction should be offset and presented as a
single amount. Preparers should ensure that
amounts that are netted in their presentation of
the tax accounts in the financial statements
reflect the right of offset within the current and
non-current classifications of the balance sheet.
Consideration should be given to disclosing the
nature and effect of significant items affecting
the comparability of the tax accounts and
effective tax rate for all periods presented.

a description of the types of temporary
differences and the types of events that
would cause those differences to become
taxable in the parent’s home country
jurisdiction
For companies that do not disclose an estimate
of the unrecorded liability, the Securities and
Exchange Commission (SEC) staff has been
requesting an explanation as to why
determination of an estimate is not practicable.
Some companies that had historically
concluded that an estimate was not practicable
have more recently begun disclosing an
estimate.

Disclosure of tax attribute carry-forwards
should be based upon the accounting
recognition and measurement criteria. A
company may wish to consider explanatory
disclosure of both the amounts claimed in tax
returns and the respective amounts benefitted
in the financial statements.

Consideration should be given to ensure that
tax accounts from different jurisdictions
(where the right of offset does not exist) are
reported separately on the balance sheet.
Preparers should ensure that the tax accounts
of different jurisdictions are not netted to the
extent there is no right of offset.

The valuation allowance for a particular tax
jurisdiction should be allocated between
current and non-current deferred tax assets for
that tax jurisdiction on a pro rata basis (see the
FASB update above for potential developments
on this topic), consistent with the ratio of
current and deferred gross deferred tax assets.
This is the case even when the valuation
allowance may only relate to one identifiable
temporary difference. Companies should ensure
that the allocation methodology is applied.
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


Financial statement amounts reported in the
consolidated income tax provision and net
income attributable to a non-controlling
interest (NCI) can differ based on whether the
subsidiary is a C-corporation or a partnership.
Explanatory disclosures may be appropriate if
the impacts of the NCI are significant.
Consideration should be given to early warning
disclosures related to significant estimates and
judgments related to income taxes. Examples
include disclosure of possible near-term
recognition or release of a valuation allowance
or a material change in an uncertain tax
position.
Companies should consider early warning
disclosures to the extent any significant
estimate or judgment may change. This early
warning disclosure may also include discussion
of any significant impact of potential tax rate
changes that are in various stages of legislative
processes. Management discussion and
analysis (MD&A) requires disclosure of known
uncertainties if it is reasonably likely that the
uncertainty will come to fruition and it is
reasonably likely to have a material impact on
financial condition or results of operations.

Unrecognised tax benefits disclosure includes
positions expected to be taken in amended tax
returns (or refund claims), as well as positions
presented directly to a taxing authority during
the course of an examination.

The required footnote disclosures for UTPs
should be provided for each of the periods
presented in the financial statements.

Companies must disclose the nature of
uncertain positions and related events if it is
reasonably possible that the positions and
events could change the associated recognised
tax benefits within the next 12 months. This
includes previously unrecognised tax benefits
that are expected to be recognised upon the
expiration of a statute of limitations within the
next year.

Uncertain tax benefits must be netted against
all available same-jurisdiction loss or other tax
carry-forwards that would be utilised. Further,
public entities are required to include all UTBs
(gross) within the UTB footnote disclosures.

Transparency in financial reporting/disclosure
remains a continued focus for regulators and
shareholders. An emerging trend has been
noted regarding shareholder groups
highlighting a lack of income tax disclosure to
the Board of Directors and Audit Committee
level. Companies should remain cognisant of
end users in drafting income tax disclosures—
particularly in quantifying financial impacts
and overall integrated reporting.
IFRS reminders
 Organisations need to consider quality of
disclosures in the financial statements. As
continued to be emphasised by the European
securities market regulator, ESMA, the focus
needs to be not on the number of items
disclosed (that could overload financial
statements with excessive detail), but rather on
the quality of the disclosed information, i.e.,
clear and complete representation of the
relevant facts that are specific to the entity and
are necessary to understand the company’s
financial performance and position.
Continued
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

As mentioned in the ESMA’s update above,
companies are expected to disclose significant
assumptions made in their business plans to
support the existence of future taxable profits
to allow utilisation of losses. In particular, the
following information needs to be disclosed:

the period used for the assessment of the
recovery of a deferred tax asset

the judgments made when determining it

the amount of tax losses carried forward
for which deferred tax assets were
recognised compared to the total tax losses
carried forward that are available for each
material tax group or entity
As also mentioned above, issuers will be
expected to disclose their accounting policy
related to material uncertain tax positions in
accordance with paragraphs 117 and 122 of IAS
1 Presentation of Financial Statements.
Tax accounting refresher
Contacts and primary authors
Global tax accounting services newsletter
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In this issue
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Accounting and
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Tax accounting refresher
Contacts and primary authors
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
andrew.wiggins@uk.pwc.com
Terry SY Tam
Asia Pacific Tax Accounting
Services Leader
+86 (21) 2323 1555
terry.sy.tam@cn.pwc.com
EMEA
Latin America
Kenneth Shives
EMEA Tax Accounting
Services Leader
+32 (2) 710 4812
kenneth.shives@be.pwc.com
Marjorie Dhunjishah
Latin America Tax Accounting
Services Leader
+1 (703) 918 3608
marjorie.l.dhunjishah@us.pwc.com
Continued
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In this issue
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Accounting and
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tax law changes
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Contacts and primary authors
Contacts
Tax accounting leaders in major countries
Country
Name
Telephone
Email
Australia
Ronen Vexler
+61 (2) 8266 0320
ronen.vexler@au.pwc.com
Belgium
Koen De Grave
+32 (3) 259 3184
koen.de.grave@be.pwc.com
Brazil
Manuel Marinho
+55 (11) 3674 3404
manuel.marinho@br.pwc.com
Canada
Spence McDonnell
Nicole Inglis
+1 (416) 869 2328
+1 (604) 806 7781
spence.n.mcdonnell@ca.pwc.com
nicole.f.inglis@ca.pwc.com
China
Terry SY Tam
+86 (21) 2323 1555
terry.sy.tam@cn.pwc.com
France
Marine Gril-Gadonneix
+33 (1) 56 57 43 16
marine.gril-gadonneix@fr.landwellglobal.com
Germany
Heiko Schäfer
+49 (69) 9585 6227
heiko.schaefer@de.pwc.com
Hungary
David Williams
+36 (1) 461 9354
david.williams@hu.pwc.com
Japan
Masanori Kato
+81 (3) 5251 2536
masanori.kato@jp.pwc.com
Mexico
Fausto Cantu
+52 (81) 8152 2052
fausto.cantu@mx.pwc.com
Netherlands
Jurriaan Weerman
+31 (0) 887 925 086
jurriaan.weerman@nl.pwc.com
United Kingdom
Andrew Wiggins
+44 (0) 121 232 2065
andrew.wiggins@uk.pwc.com
United States
David Wiseman
+1 (617) 530 7274
david.wiseman@us.pwc.com
Global tax accounting services newsletter
Introduction
In this issue
Home Subscription
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
andrew.wiggins@uk.pwc.com
National Professional Services
Group Partner
+1 (973) 236 7064
steven.schaefer@us.pwc.com
Katya Umanskaya
Koen De Grave
Global and US Tax Accounting
Services Director
+1 (312) 298 3013
ekaterina.umanskaya@us.pwc.com
Belgium Tax Accounting
Services Leader
+32 (0) 3 259 31 84
koen.de.grave@be.pwc.com
Tax accounting refresher
Contacts and primary authors
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