With all due respect, the OECD’s BEPS project was a fiasco, accomplishing little of any positive value and opening up a Pandora’s box with its focus on “value creation” in the context of transfer pricing. Despite all the “happy talk” coming out of the OECD and all the talk of… – Continue reading
On October 5, the OECD issued it formal recommendations on the Base Erosion and Profit Shifting (BEPS) Action Plan. These recommendations have been subsequently adopted by the G20. We acknowledge the monumental effort that has been put forth to produce a modernized international system of tax rules through the BEPS… – Continue reading
Although the British Virgin Islands is often seen as an offshore tax haven, a closer look shows such opinions may be overstated There is a stereotypical image of the so-called ‘tax haven’ for ‘shady people to put their money’. While it is true that BVI Finance enjoys warm, sunny weather… – Continue reading
The international community led by the had initiated the (BEPS) project a few years ago with the aim of ensuring that profits are taxed where economic activities are performed and where value is created. Governments, and social groups have been voicing their concern over the past decade that multinational enterprises… – Continue reading
ONE | A NEW LIBERAL GOVERNMENT Elected in October 2015, Canada’s new Liberal government has proposed a tax platform featuring significant changes, including a four per cent increase (to 33 per cent) in the federal tax rate for individuals on income over C$200,000 and a 1.5 per cent drop in… – Continue reading
On Nov. 18, 2015, reforms to the Mexican Income Tax Law (MITL), Tax Code, Excise Tax and Federal Income Law for 2016 (collectively, the Tax Reform) were published in the Federal Gazette. The Tax Reform reestablishes measures to promote savings and increase incentives for doing business in Mexico, some of… – Continue reading
Current system viewed as unfair and too easy to circumvent Abolition of corporation tax is to be considered by a new cross-party group of MPs and peers who will subject ministers and business leaders to public interrogations in a bid to secure fairer and more responsible tax policies. The all-party… – Continue reading
Measure tries to keep firms from exploiting tax law variations Foreign and local businesses with annual sales of 100 billion won ($85 million) or more, and over 50 billion won in transactions with overseas entities must report international transactions to the tax authority starting next year. Known as the “Google… – Continue reading
ICAEW says OECD has done a good job but success will depend on actual implementation by individual countries The new All-Party Parliamentary Group (APPG) on Responsible Tax has identified three it wishes to look at initially: the work of the OECD on its base erosion profit shifting (BEPS) Action Plan;… – Continue reading
The Treasury Department released a proposal on Monday that would require certain companies to annually report information relating to income and taxes on a country-by-country basis. The proposal would apply to businesses that are the parents of multinational enterprise groups with annual revenue of at least $850 million. The categories… – Continue reading
IT is ironic that what was almost at the centre of the BEPS project has ended up in not having a concrete agreement and with a vague promise of some review by the year 2020. One may recall that it was the big digital companies and their tax affairs that… – Continue reading
The Protocol amending the Multilateral Convention on Mutual Administrative Assistance in Tax Matters will lead to substantially more transnational identity theft, crime, industrial espionage, financial fraud, and the suppression of political opponents and religious or ethnic minorities by authoritarian and corrupt governments. It puts Americans’ private financial information at risk…. – Continue reading
The Bundesrat (upper house of the German parliament) approved the Law on the Automatic Exchange of Financial Account Information (Finanzkonten-Informationsaustauschgesetz) on 18 December 2015. Financial institutions face new reporting obligations and duties of care under this law. The new legislation requires financial institutions to provide the German Federal Central Tax… – Continue reading
The European Parliament has spelt out the legal steps needed to improve corporate tax transparency, coordination and an EU-wide policy convergence in a resolution voted on this week. Parliament’s drive to persuade EU member states to act to counter aggressive corporate tax planning and evasion by multinationals in Europe was… – Continue reading
Turkey’s ruling Justice and Development Party (AKP) government, in power for 13 years, has been notoriously lax and often late when it comes to implementing stringent rules controlling money in order to ensure better transparency in financial movements, halt tax evasion, prevent illicit funding and disrupt money laundering activities. That… – Continue reading
Not only is Dec. 31 the deadline for any last-minute, year-end tax planning you may be contemplating, but it may also be the last day to come clean to the tax man if you still have an undisclosed Swiss bank account. If that’s you, consider getting your act together and… – Continue reading
Where it happens does not matter. Portugal or overseas, whether its rental income, bank interest, bond yields, dividends, or even gains from the sale of a property, such personal financial information will be automatically shared from 1st January 2016. For many who have undergone financial planning, or have been involved… – Continue reading
Where it happens does not matter. Portugal or overseas, whether its rental income, bank interest, bond yields, dividends, or even gains from the sale of a property, such personal financial information will be automatically shared from 1st January 2016. For many who have undergone financial planning, or have been involved… – Continue reading
On December 8, there was a brief note in the media about the fact that Malta had managed to include a reference to flexibility into a European Council communiqué on taxation. You would be forgiven for overlooking it, assuming it was just a pedantic attempt to score political points. Think… – Continue reading
Initiated by the Organisation for Economic Cooperation and Development in 2013 and endorsed by the G-20, the OECD’s “Action Plan to Address Base Erosion and Profit Shifting (BEPS)” includes 15 key areas to encourage more transparency, better reporting and more cooperation between countries in which multinational companies operate. On October… – Continue reading
In the wake of the final OECD BEPS reports issued in October, the European Council adopted amendments to Directive 2011/16/EU providing for the automatic exchange of information concerning advance cross border rulings (ACBR) and advance pricing arrangements (APA) between Member States. The amendments, which will come into force from 1… – Continue reading
16/12/2015 – Today the People’s Republic of China became the 77th jurisdiction to sign the Multilateral Competent Authority Agreement (MCAA), which allows it to move forward with plans to activate automatic exchange of financial account information in tax matters and commence exchanges with other countries in 2018. The G20 Leaders… – Continue reading
The common reporting standard framework was first released by the Organisation for Economic Co-operation and Development (the “OECD”) in February 2014 as a result of significant political will demonstrated by the G20 members to endorse a global model of automatic exchange of information and increase international tax transparency. On 21… – Continue reading
Summary In the March 2015 Budget the Chancellor announced tough new sanctions for tax evasion, intended to have a deterrent effect. After a period of consultation, the intention to proceed with these measures was confirmed in the 2015 Autumn Statement. In summary, the measures to be implemented are: A new… – Continue reading
India and Korea on December 9 agreed to suspend collection of taxes during the pendency of Mutual Agreement Procedure (MAP). This MoU will relieve the burden of double taxation for the taxpayer in both the countries. Two days later, India and Japan signed a protocol for amending the existing convention,… – Continue reading
For the Socialist Senator Roberto Zanetti, the reform is an open-heart surgery, which must be done with great accuracy. Under pressure from the EU, G20 and the OECD, also Switzerland is obliged to give up his special tax regimes for holding companies and management companies. After years of negotiations with… – Continue reading
The Belgian Minister of Finance has just shared new insights on how Belgium will be addressing the outcome of the OECD/G20 project in relation to Base Erosion and Profit Shifting (“BEPS”). He opted to do so via the “Plan to combat tax fraud”. The title of his policy note is… – Continue reading
According to Baroness Neville-Rolfe, Parliamentary Under Secretary of State at the Department for Business, Innovation and Skills, the United Kingdom “is at the forefront of a dramatic increase in transparency about company ownership” in developed countries. However, it is the UK which is going to provide the testing ground for… – Continue reading
Companies operating cross border through presence of Branch offices, Liaison and representative offices, appointed distributors and agents should closely watch the changes coming through in international tax norms. OECD and G20 countries adopted a 15 point action plan to address Base Erosion and Profit Shifting (BEPS) and Action Point 7… – Continue reading
Global Financial IntegrityGlobal Financial Integrity (GFI) on 8 December 2015 released the Global Illicit Financial Flows Report 2015 entitled Illicit Financial Flows from the Developing Countries: 2004-2013. This study is GFI’s 2015 annual global update on illicit financial flows from developing economies. It is the sixth annual update of GFI’s… – Continue reading
In 2013, the 39th G8 summit in Lough Erne committed to reform the international tax system. The G8 Lough Erne Declaration stated that such reforms would benefit developing countries. The G20 declaration in St Petersburg 2013 also stated specifically that “Developing countries should be able to reap the benefits of… – Continue reading
Akhilesh Ranjan, joint secretary (foreign tax), who led India’s initiative in the BEPS project, candidly shared his views on India’s plans for its implementation and what lies in the future. The fundamental principle of the BEPS project, is that income of MNCs should be taxed in that country where economic… – Continue reading
It is time for re-regulation; Europe is strengthening its AML/CFT measures in order to lower current terrorist financing (TF) risks. “Money is the lifeblood of terrorist operations,” declared George Bush after the 9/11 attacks. French finance minister Michel Sapin has beaten the same drum when he recently claimed that “the… – Continue reading
Legislative amendments to the Tax Administration Act were affected in the Tax Administration Laws Amendment Bill, 2015, in order to implement a scheme under which SARS may require South African financial institutions to collect information under the OECD Standard for Automatic Exchange of Financial Account Information in Tax Matters, which… – Continue reading
On December 9, 2015 the UK HM Revenue & Customs (HMRC) published a policy paper titled: “Corporation Tax: anti-hybrid rules”. Next to publishing the policy paper the UK Government also announces that on December 22, 2015 a series of examples illustrating the application of the hybrid mismatch rules will be… – Continue reading
SOUTH Africa ranks seventh among developing countries in terms of illicit financial outflows, a Washington-based research organisation has found. Illicit outflows from the country are of great concern to the Treasury, which has introduced a number of measures to curb it, particularly the outflows achieved through profit shifting by large… – Continue reading
The Cabinet has submitted a bill to the Parliament Speaker’s Office for presentation and approval by the legislature of an agreement with the US that concerns the sharing of information between the countries to prevent tax fraud. A letter accompanying the legislation sent to the speaker’s office on Nov. 19… – Continue reading
WASHINGTON: India ranks fourth in black money outflows with a whopping USD 51 billion siphoned out of the country per annum between 2004-2013, a US-based think-tank’s report said today. Notably India’s defence budget is less than USD 50 billion. China tops the list with USD 139 billion average outflow of… – Continue reading
In Paris on the occasion of the COP21, the Honourable Billy Graham Talagi, Minister for Ministry of Natural Resources of Niue signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters in the presence of Deputy Secretary General Rintaro Tamaki. Previously, Israel signed the Multilateral Convention on Mutual Administrative… – Continue reading
On 8 December 2015, the Council adopted a directive aimed at improving transparency on tax rulings given by member states to companies in specific cases about how taxation will be dealt with. The directive is one of a number of initiatives aimed at preventing corporate tax avoidance. It will require… – Continue reading
MUMBAI: India has been an active participant in the Base Erosion and Profit Sharing (BEPS) action plan, the final package of which was rolled out by the Organisation for Economic Co-operation and Development (OECD) in October. The action points, set down by the OECD, aim at closing loopholes that enable… – Continue reading
WASHINGTON Illicit financial flows or black money from developing and emerging economies surged to US$1.1 trillion or a staggering 4 percent of the developing world’s GDP in 2013, according to a study released Wednesday by Global Financial Integrity (GFI), a Washington, DC-based research and advisory organization. The cumulative illicit outflows… – Continue reading
The new agreement marks the end of bank secrecy between San Marino and the EU. As of 2017, San Marino and EU Member States will automatically exchange information on the financial accounts of one another’s residents. Pierre Moscovici, Commissioner for Economic and Financial Affairs, Taxation and Customs, said: “This agreement… – Continue reading
The government will look into compelling taxpayers to report to authorities if they receive consulting to reduce their tax obligations. The Ministry of Strategy and Finance said Sunday that it will review the measure as a follow-up to the Base Erosion and Profit Shifting program approved at last month’s Group… – Continue reading
The Base Erosion and Profit Shifting (BEPS) project is an initiative being pursued by the Organization of Economic Cooperation and Development (OECD) to curtail perceived exploitation of international tax rules and loopholes by multinational enterprises (MNEs). The OECD’s BEPS project was initiated in 2013 at the request of the Group… – Continue reading
Pierre Gramegna says “challenging and long lasting” impact of the terrorist and refugee crises means countries have “no choice” but to ramp up spending Terrorist attacks are the biggest threat facing the European Union and countries have “no choice” but to tear up budget rules and ramp-up spending in order… – Continue reading
The Treasury was forced to defend this week’s Autumn Statement and Spending Review announcements last night after the influential Institute for Fiscal Studies (IFS), an independent research institute, said there was just a 50-50 chance Osborne would hit his target of a surplus in 2019-2020. While saying the government will… – Continue reading
MUMBAI: India has been an active participant in the Base Erosion and Profit Sharing (BEPS) action plan, the final package of which was rolled out by the Organisation for Economic Co-operation and Development (OECD) in October. The action points, set down by the OECD, aim at closing loopholes that enable… – Continue reading
From the start of 2016, multinational companies found to be avoiding tax will have pay back the tax owed, plus a 100 per cent penalty, reports ZD Net. The Australian Greens have voted with the Coalition to pass legislation that will see multinational companies with annual revenue above AU$1 billion… – Continue reading
Multinationals in India will soon have to forgo to a great extent the flexibility in managing their tax outgo in the country and have to report their global operations in elaborate detail to the tax authorities here. This is because New Delhi is set to adopt a new regime to… – Continue reading
