Category: G20

Cayman Islands: Fiscal Transparency In The Cayman Islands

Introduction The Cayman Islands have an extremely open, accountable and transparent government and regulatory system. Despite the dated stereotype, the Cayman Islands have promoted transparency regulations and initiatives for many years.  In May 2000, the Cayman Islands made commitments to the Organisation for Economic Co-operation and Development (the “OECD“) to… – Continue reading

Treasury proposes five major changes to the U.S. Model tax treaty

On May 20, 2015, the U.S. Treasury Department (“Treasury”) released five sets of proposed revisions to the U.S. Model Income Tax Convention (“Model Treaty”) for public comment. The Model Treaty was last updated in 2006. The purpose of the proposed revisions is to ensure that the United States maintains the… – Continue reading

Australian Taxation Office issues new Practice Statement on Advance Pricing Arrangements

The tax and in particular the transfer pricing arrangements of multinationals is currently under the spotlight both internationally, through the OECD/G20 BEPS project, and domestically in Australia, by way of the Senate inquiry into corporate tax avoidance. This has resulted in new legal measures being adopted (such as the DPT… – Continue reading

The OECD BEPS Project, part III: the impact of BEPS in the United States

This article is the third in our current three part series discussing various impacts of the Organisation for Economic Co-operation and Development’s (OECD’s) efforts to address the perceived global tax problem of base erosion and profit shifting (BEPS). The first article provided an overview of the key aspects of the… – Continue reading

International tax update- August 2015

United Kingdom Budget The Chancellor of the Exchequer delivered his Summer Budget to the United Kingdom (UK) Parliament on 8 July 2015. A number of personal, corporate and indirect tax-related measures were announced in the Budget including a reduced corporate tax rate; introduction of a bank corporation tax surcharge; a… – Continue reading

Global Tax Transparency: FATCA, CRS, European FATCA

Understanding FATCA and having a comprehensive FATCA compliance program is essential for financial firms to limit non-compliance risk and meet obligations with relevant IGA’s. The US has made inroads on the Exchange of Information front and tax havens like Switzerland have declared a willingness to meet or even exceed OECD… – Continue reading

UK: BEPS and tax structuring – how does it affect the shipping industry?

There has been much recent focus on tax structures employed by multi-national corporations. This has led to an initiative, spearheaded by the OECD, to combat “base erosion and profit shifting”, or BEPS. The shipping industry is likely to be affected both directly and indirectly by the BEPS initiative – directly,… – Continue reading

Tax noose tightening for global firms

Globalisation has brought many benefits in terms of cross?border trade, efficiency, competition and the free movement of goods and labour. But it has also allowed multinational corporations (MNCs) much greater freedom to reconfigure the location of manufacturing, operations, sales and corporate services in ways which channel reported profits ? and… – Continue reading

Third party returns – exchange of information in accordance with international tax standards

In order to provide the necessary legislative amendments required to implement the tax proposals that were announced in the 2015 National Budget on 25 February 2015, the National Treasury (Treasury) published the 2015 Draft Tax Administration Laws Amendment Bill (TALAB) on 22 July 2015 for public comment. One of the… – Continue reading

Supply chain planning in the post-BEPS era: five questions for MNEs

As governments around the world establish austerity measures to compensate for decreases in tax receipts, a new catch phrase has emerged: double non-taxation. Double non-taxation is the phrase used by governments to denote untaxed or lightly taxed profits that result from effective, legal tax planning techniques. These techniques include application… – Continue reading

Global Reform of Tax Systems to Hit Insurance Industry: London’s IUA

A sweeping global reform of tax systems is under way and will have profound implications for the insurance industry, the London-based International Underwriting Association has warned. Responding to public concerns about tax evasion, the G20 major economies have ordered a major shift towards greater cooperation between tax authorities. This work… – Continue reading

Cyprus: The Cyprus Intellectual Property Rights ‘Box’ – A Limited Time Opportunity

In May 2012, Cyprus introduced a package of incentives and tax exemptions relating to investment in intellectual property rights, commonly known as an “IP box.” Intellectual property projects are particularly susceptible to cross-border planning by reason of the mobility of intellectual property rights, which do not consist of physical assets… – Continue reading

Treasurer Joe Hockey says United States is looking to take share of Australia’s tax base

Treasurer Joe Hockey has taken aim at the United States for dragging its feet on taxing multinationals such as Google, and says the Obama administration now wants to come after Australia’s tax base. Australia has been working with the United Kingdom on a local version of Britain’s ‘Google tax’ to… – Continue reading

Key pillar of the Beps process is to align profit with value creation

OECD guidance needs to be clear otherwise the process could favour the bigger nations In Paris last week, as Angela Merkel and Francois Hollande discussed events in Greece, the international tax system was being discussed in an underground meeting room at OECD headquarters. For almost two days tax authority delegates… – Continue reading

Globalist Assault on Tax Competition Rouses Opposition

As part of what experts call a war on tax competition and low taxes, a coalition of high-tax governments from around the world is working to erect a radical new planetary taxation regime that would further smother what remains of financial privacy and national sovereignty while seriously harming the global… – Continue reading

World looks to Ethiopia to break deadlock over financing new development goals

NAIROBI (Thomson Reuters Foundation) – Negotiators locked horns until 2 a.m. some nights in New York this past month, trying to agree on a way to finance the United Nation’s bold new global development agenda — without success. The disputed 31-page document is headed to the Ethiopian capital, Addis Ababa,… – Continue reading

ATO warns multinationals over use of Singapore, Swiss and other offshore hubs

The Australian Taxation Office has warned companies it will be focusing on money attributed to offshore marketing hubs and will use its stronger transfer pricing powers to go after them, reports the Sydney Morning Herald. Australian companies sent more than AU$100 billion to related parties in the low-tax nation of… – Continue reading

Japan MoF names Masatsugu Asakawa as top financial diplomat

Japan’s Ministry of Finance said international policy veteran Masatsugu Asakawa will become the country’s top financial diplomat, whose tasks include co-ordinating with other nations and the IMF as well as arranging currency interventions. Asakawa’s broad network with policymakers both inside and outside Japan puts him in an ideal position to… – Continue reading

United Kingdom: Overview of Tax Regime

The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading

OECD backs Guernsey as a cooperative jurisdiction

The Organisation for Economic Cooperation and Development (OECD) – the leading international standards-setter for tax transparency and cooperation – has underlined Guernsey’s reputation as a cooperative jurisdiction, reports Guernsey Finance. Monica Bhatia, Head of the Secretariat of the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes… – Continue reading

Tax:Company Warns Multi-Nationals Against Cheating

Oxfam, a multinational organisation, says Africa is haemorrhaging billions of dollars because multinational companies are cheating African governments out of vital revenues by not paying their fair share in taxes. This is contained in a statement issued by the organisation, interested in combating poverty, and made available to newsmen in… – Continue reading

Cyprus: OECD Releases New Measures For Implementation Of A BEPS Country By Country Reporting Plan

On June 8th 2015, the OECD released a new package of measures for the implementation of a new Country-by-Country (CbC) reporting plan developed under the OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS) Project, aimed at improving transparency in international tax matters. The CbC reporting plan was founded… – Continue reading

China Deepens Ties with OECD

Premier Li Keqiang has strengthened China’s cooperation with the Organization for Economic Cooperation and Development (OECD) after he signed two agreements with the international economic organization in Paris on Wednesday. China has also been officially made a member of the Development Centre of the Organization for Economic Cooperation and Development… – Continue reading

Coalition can find a tasty replacement for the Double Irish

Ireland’s attractively low rate of corporate taxation is once again under pressure with the recent release of the European Commission’s new action plan to tackle tax avoidance. The commission has been prompted into this politically ambitious move by public outcry over big, usually American, companies avoiding tax in the EU…. – Continue reading

A Perspective on BEPS From Russia

OECD and G20 Action Plan on Base Erosion and Profit Shifting (BEPS) was adopted in 2013. It consists of 15 actions including transfer pricing, taxation of controlled foreign corporations (CFC), digital commerce, hybrid instruments, international information exchange, tax treaty shopping etc. In 2013, OECD working group prepared draft documents regarding… – Continue reading

International tax update – July 2015

OECD common reporting standard On 3 June 2015, the Treasurer announced that Australia had signed the Organisation for Economic Co-operation and Development’s (OECD) common reporting standard (CRS) Multilateral Competent Authority Agreement which enables automatic exchange of CRS information between countries. Australia proposes to implement the CRS from 1 January 2017,… – Continue reading

Tax treaty with Mauritius blocks outflow

A new treaty makes it more difficult for companies to take advantage of tax loopholes to avoid their financial obligations. Globally, initiatives are afoot to close tax loopholes and South Africa is one of the frontrunners – its new treaty with Mauritius removes the allure for tax-shy corporates doing business… – Continue reading

Manhattan DA: Cayman ‘better positioned’ to fight terrorism finance

The Cayman Islands is better positioned to police terrorism financing than the U.S., an American congressional subcommittee heard Wednesday. The comments came from New York County District Attorney Cyrus Vance, who was called before the U.S. House Task Force to Investigate Terrorism Finance. “On a near daily basis, we encounter… – Continue reading

Cantillon: Dublin incinerator funding from Luxembourg a burning issue

DUBAI: This week the UK’s National Crime Agency (NCA) published their 2015 National Strategic Assessment. The Assessment presents a comprehensive picture of the threat to the UK from serious and organised crime, and helps to inform the work of the NCA and their international partners, including in the UAE. Some… – Continue reading

Amazon’s UK business paid just £11.9m in tax last year

Online retailer’s Luxembourg unit took £5.3bn sales from British internet shoppers, a rise of 14%, but Amazon.co.uk Limited recorded profit of just £34.4m Amazon’s booming UK business paid just £11.9m of tax last year, while the online retailer’s Luxembourg unit took £5.3bn of sales from British internet shoppers without being… – Continue reading

Insurance tax changes loom on the horizon

Conor Hynes and Ronan Connaughton of Deloitte Ireland explore the impending changes arising from BEPS Action 7 and the Skandia case and provide insight on the potential tax impact for the insurance industry. The Greek philosopher Heraclitus is attributed with the saying, “the only thing that is constant is change”…. – Continue reading

Define a tax haven, business lobbies tell government

Before going after multinationals that channel profits through tax havens and low-tax nations, you must define what one is, business lobbies have told the Abbott government. Treasurer Joe Hockey announced in the May budget that the government would be strengthening anti-avoidance laws to go after 30 companies with over $1… – Continue reading

Poland removes Bermuda from ‘blacklist’

A controversial Euro list of dodgy tax jurisdictions that included Bermuda has been dealt a blow after Poland said the Island should not have been included on its submission. The move came after the European Commission unveiled the 30-jurisdiction ‘blacklist’ of non-cooperative tax jurisdictions singled out by member states. Poland… – Continue reading

Complex tax laws a goose to overseas firms

Someone once said that a good tax system enables the government to pluck the feathers from the taxpaying goose with the least amount of hissing, says Rod Houng-Lee. The least amount of hissing occurs when the law is simple and clear. The hissing increases exponentially when the law is more… – Continue reading

Crackdown on multinational tax avoidance likely to be thwarted, says expert

The G20’s efforts to crack down on multinational tax avoidance are likely to be defeated by national self-interest, particularly from the United States, one of Australasia’s top tax advisers says, reports the Sydney Morning Herald. Rod Houng-Lee, formerly Asia Pacific Tax Leader head of tax in Asia Pacific for big-four… – Continue reading

UK trips up EU plan to ham string industrial-scale corporate tax avoidance

Britain will not adopt new EU measures to tackle large-scale tax avoidance by multinational companies, the financial secretary to the Treasury has said. Brussels hopes to implement a longstanding tax harmonization plan to set common rules across member states, thereby closing legal loopholes multinationals currently exploit. A German member of… – Continue reading

Global net closes on tax dodgers

International tax rules will soon change, but companies’ behaviour may change sooner. There will soon be fewer places for multinational companies and ultra-rich individuals to squirrel away money. In November leaders of the G20 are expected to adopt a full range of measures to curb the practices of base erosion… – Continue reading

‘Surprise’ at Guernsey inclusion on EU ‘non-cooperative’ blacklist

Guernsey’s Chief Minister and Commerce and Employment Minister have expressed their astonishment that Guernsey has been included on a list of 30 so-called ‘non-cooperative’ non-EU jurisdictions, which was published today, reports Guernsey Finance. The list consolidates national tax ‘blacklists’ as they stood six months ago, and includes any jurisdiction on… – Continue reading

Cayman on new EU blacklist

Government appeared to brush off the latest blacklisting of the Cayman Islands when it released a short statement on Wednesday at around 5pm following revelations by the EU that the jurisdiction had been cited as facilitating tax evasion, reports the Cayman News Service. “It is unfortunate that the EU black… – Continue reading