Category: Regulatory

Interpreting double tax treaties in light of the BEPS multilateral instrument

Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL...

The Finnish Supreme Administrative Court confirms that the business model chosen by parties must be respected in transfer pricing context

The Finnish Supreme Administrative Court published on 13 September 2017 precedent 2017:145 that further clarifies the scope of application of the Finnish transfer pricing adjustment provision (Act on Assessment Procedure (“AAP”) Section 31). In its previous landmark precedent KHO 2014:119 the Supreme Administrative Court stated that the so-called re-characterization of...

US Hearing On Improving IRS Appeals Process

On September 13, the US Ways and Means Oversight Subcommittee launched a hearing on improving the resolution process for taxpayer disputes and appeals with the Internal Revenue Service. The hearing is said to be the fourth in a series of attempts to reform and improve the IRS appeals process. “In...

Econ experts laud tax reform plan

MANILA, Philippines — The Foundation for Economic Freedom (FEF) has expressed support for the tax reform program being pushed by the Department of Finance, saying this will lead to better lives for Filipinos. “The comprehensive tax reform program lays a solid foundation for the government’s vision of inclusive growth, improved...

Donohoe says Ireland opposes ‘equalisation tax’ at EU meeting

The proposals plan to tax giant digital companies on turnover rather than profits EU finance ministers have agreed to step up technical work on harmonising the taxation of the giant digital companies with a view to debating “possible solutions” at their December meeting. The ministerial consensus was a significant setback...

EU Seeks a Digital Tax to Stem the ‘Bags of Money’ Lost to Loopholes

Finance ministers discuss new tax plans in Tallinn, Estonia France’s Le Maire says EU citizens ‘outraged’ by situation European Union finance ministers are developing a new way to tax digital companies such as Amazon.com Inc. and Facebook Inc. to raise money from an industry that they say provides less than...

Kazakhstan Signs FATCA Agreement with US

Kazakhstan and the United States have signed a Model 1 FATCA Intergovernmental Agreement (IGA), which will enable the automatic exchange of financial information on each country’s resident taxpayers to support tax enforcement efforts. The agreement was signed in Astana on September 11, 2017. Kazakh Minister of Finance Bakhyt Sultanov emphasized...

Tax evaders set to face action: CBDT chairman Sushil Chandra

CBDT chairman Sushil Chandra says income tax dept will soon conclude probe into financial dealings of about 100,000 individuals suspected of tax evasion New Delhi: The income tax department will conclude its investigations into the financial dealings of about 100,000 individuals suspected of tax evasion and persuade many other assessees...

Tax Avoidance Firm Loses ‘HMRC Approved’ Ad Challenge

A ruling from advertising watchdogs that carrying the HM Revenue & Customs on advertising materials is misleading leaves the way open for government departments to challenge firms over misleading consumers. The Advertising Standards Authority (ASA) investigated a web site and leaflet published by tax and wealth advisors Knight Wolffe after...

Multinationals would face mandatory tax on offshore profits, Steven Mnuchin says

Multinational corporations with profits held overseas would face a mandatory one-time tax as part of the planned Republican tax legislation, Treasury Secretary Steven Mnuchin said Wednesday. “There will be a ‘deemed tax’ as a one-time charge,” Mnuchin said in an interview with Fox News at the Treasury. U.S. companies have...

Supermarkets under spotlight for tax evasion

Three major supermarkets are under investigation for tax evasion by the Fiji Revenue and Customs Services. In an exclusive interview with FBC News, Revenue and Customs chief executive, Visvanath Das says the non-compliance by any one of the three supermarkets could amount an average of fifty million dollars each. Hot...

Slow UK aid for hurricane-hit islands linked to tax haven ties

Anguilla’s ex-attorney general says UK government may fear exposing its role in Caribbean territories’ tax arrangements Aid offered by the British government to its hurricane-battered territories in the Caribbean has been dismissed as “derisory” by a former attorney general of one of the worst-hit islands. Rupert Jones, who completed a...

OECD releases guidance to ensure BEPS country-by-country reports are used appropriately.

Canada has implemented the country-by-country reporting requirement for large multinational enterprises (MNEs) contained in the 2015 Final Report on Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan.  Canada’s legislation is found in s. 233.8 of the Income Tax Act (Canada), and is supported by the...

Panama probe: First prosecutions are taken to court for off-shore tax evasion

While at the beginning of the year (The Indian Express, March 16, 2017) the number of requests sent by India stood at 283 cases, it has now crossed 300. And while the number of replies received from among these 13 jurisdictions stood at 165, that figure has now crossed 240....