21 October 2016

Iceland passes bill to implement OECD BEPS Action 4 and Action 13 recommendations

The Icelandic Parliament passed Bill No. 787 on October 13, that among other things, implements some of the recommendations contained in Action 4 (interest deduction limitation) and Action 13 (transfer pricing documentation) of the Organisation for Economic Co-operation and Development (OECD)/G20 Base Erosion and Profit Shifting (BEPS) project. In relation to Action 4, a fixed ratio rule will cap the amount of Icelandic tax relief for gross interest expense from related parties to 30% of taxable earnings before interest, taxes, depreciation and amortization (EBITDA) calculated per entity. Regarding Action 13, the legislation introduces Country-by-Country (CbC) reporting.

A Tax Alert prepared by Ernst & Young Iceland, and attached below, provides additional details.

———————————————
ATTACHMENT

Full text of Tax Alert 2016-1799

Document ID: 2016-1799