Category: Framework

Capital gains / Capital Gains Tax / Dividends / Framework / G20 / Profit Shifting / Revenue / Royalties / Withholding Tax

Ireland: Aviation Finance & Leasing 2022

Published by: Mondaq - June 13, 2022

Financing structures involving Irish entities often employ the use of a special-purpose vehicle ("SPV"), which is a company established specifically to hold title to the aircraft subject to the financing and to lease those aircraft to the operators. Ireland is a popular jurisdiction for the establishment of SPVs due to the numerous double-tax treaties in place between Ireland and other countries, many of which specifically refer to aviation in their text. Ireland is also attractive due to the confidence in the legal and court system (which is broadly based on English common law) and the number of aviation experts and leasing companies based in Ireland. ... - Continue reading

Business / Corporate Tax / Digital Services / Framework / G20 / Jurisdiction / OECD / Offshore / Offshore Tax Evasion / Revenue / Tax Authority / Tax competition / Tax Evasion / Tax treaties

What is the global minimum corporate tax?

Published by: Business Standard - June 13, 2022

The global minimum corporate tax on MNCs was aimed at discouraging them from shifting profits to low-tax countries. But it will reduce the incentives to attract investment in developing countries ... - Continue reading

Business / Compliant / Framework / OECD / Permanent establishment / Tax Credit

 The Pillar Two model rules: a train wreck in the making

Published by: MNE Tax - March 10, 2022

On December 20, 2021, the OECD issued model rules for Pillar Two—the 15% global minimum tax. It is a brutally complex 70-page package and introduces two fundamental changes to the October 2021 OECD framework: a new Qualified Domestic Minimum Top-Up tax (QDMTT) and a significant rewrite of the Undertaxed Payment Rule (UTPR). ... - Continue reading

Automatic Exchange of Information / Framework / Multilateral Competent Authority Agreement / OECD / Regulatory / Revenue

Turkey: List Of Countries That Will Exchange Financial Account Information With Turkey Are Updated

Published by: Mondaq - January 8, 2021

As known, Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (the Agreement) was signed on 21.04.2017 after 6 years by 107 countries so far, including Turkey which approved the Agreement on 21.12.2019. According to the Agreement, the signatory countries will share the financial account information of the resident of the relevant country which is collected from the financial institutions every year automatically without any request. ... - Continue reading

Framework / G20 / Lease / Multinationals / OECD / Permanent establishment / Revenue / Transfer pricing

Countries launch review of country-by-country reporting framework for multinational groups

Published by: MNE Tax - February 9, 2020

An OECD-led group of 137 countries that work together on multinational group tax issues has released a consultation document and has requested public feedback to assist in a planned review of country-by-country reporting. The countries, known as the “Inclusive Framework on BEPS,” also scheduled a public consultation on the topic for March 17.
... - Continue reading

Australia / Base Erosion & Profit Shifting / Framework / Israel / Tax Authority / Tax Avoidance / Tax treaties

Tax treaty ratified

Posted On: December 12, 2019

‘The new tax treaty between Australia and Israel will ensure the economic, trade and commercial relationship between our two countries is strengthened’. A “HISTORIC” new tax treaty between Australia and Israel has been hailed as “representing an important milestone in removing tax barriers and facilitating trade and investment” between the… – Continue reading

Base Erosion & Profit Shifting / Business / Corporate Tax / Country-by-Country (CbyC) Reporting / Framework / Multinationals / OECD / Revenue / Tax Avoidance / USA

GRI issues international corporate tax reporting standard

Posted On: December 9, 2019

The Global Reporting Initiative has issued a new international tax reporting standard that aims to ensure multinational companies are much clearer about how much they pay in taxes, and where. While the standard has no legal force, it could influence the ongoing debate in the U.S. and abroad on how… – Continue reading

Business / Europe / Framework / Jurisdiction

OECD consulting on digital tax proposal

Posted On: October 9, 2019

The OECD today published for stakeholders’ comments a proposal to advance international negotiations to ensure that multinational enterprises (MNEs), including digital companies, pay tax wherever they have significant consumer-facing activities and where they generate profits. The proposal – Secretariat Proposal for a Unified Approach – would re-allocate some profits and… – Continue reading

Double Taxation Agreement / East Africa / Framework / Tax Evasion / Tax treaties

East Africa bloc mulls regional tax treaty framework to boost integration

Posted On: October 1, 2019

NAIROBI, Oct. 1 (Xinhua) — The East Africa Community (EAC) bloc plans to develop a regional tax treaty framework to boost regional integration, an official said on Tuesday. Doris Akol, commissioner general, Uganda Revenue Authority told Xinhua in Nairobi that once the treaty is in place the trading bloc will… – Continue reading

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