CBDT issues final rules for Master File and Country-by-Country reporting NEW DELHI, NOV 1: The Central Board of Direct Taxes (CBDT) has notified the final rules for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country (CbyC) report. This is largely in line with the draft… – Continue reading
The Chartered Institute of Taxation, the UK tax professionals representative body, has urged lawmakers globally to pause for thought on the direction being taken on the taxation of the digital economy. It is urging that any measures to improve the tax rules covering the digital economy must be developed and… – Continue reading
Introduction The Organisation for Economic Co-operation and Development (OECD) is an economic organisation made up of 35 member countries, with the aim of encouraging economic progress and world trade. In 2015, the OECD developed the Base Erosion and Profit Shifting (BEPS) Project, made up of reports on 15 action plans,… – Continue reading
The OECD’s Anti Base Erosion and Profit Shifting Initiative (BEPS) significantly affects current transfer pricing regimes regarding intangibles, documentation and dispute resolution. Why is Transfer Pricing relevant for BEPS? To avoid base erosion and profit shifting of multinational companies, the OECD initiated an action plan consisting of 15 actions with… – Continue reading
Jude Scott, CEO of the Cayman Islands’ financial services promotion agency, Cayman Finance, has taken aim at a report labeling the territory as a “tax haven.” The report on international financial centers, issued by the non-profit US Public Interest Research Group and the Institute on Taxation and Economic Policy, also… – Continue reading
Peru takes one step further in the eradication of tax avoidance and evasion after signing the Convention on Mutual Administrative Assistance in Tax Matters with the Organisation for Economic Co-operation and Development (OECD). Deputy Director of the OECD‘s Centre for Tax Policy and Administration Grace Perez-Navarro affirmed these two crimes… – Continue reading
The Japanese National Tax Agency (NTA) has released guidance for taxpayers on the mutual agreement procedure (MAP), in line with the recommendations of the OECD’s Base erosion and profit shifting (BEPS) Action 14 Final Report. The guidance is intended to supplement the Commissioner’s Directive on the Mutual Agreement Procedures, which… – Continue reading
Oman has become the latest country to agree to implement the base erosion and profit shifting minimum standards by signing up to the BEPS Inclusive Framework. In implementing the minimum standards, countries agree to remove harmful tax provisions in their domestic tax regimes, amend their tax treaty rules to prevent… – Continue reading
THE Bahamas yesterday upgraded its tax information exchange agreement with Finland to the automatic variety, as it bids to meet global standards by September 2018. K P Turnquest, deputy prime minister, signed the Protocol to Amend the Tax Information Exchange Agreement between the Bahamas and Finland, with the latter’s ambassador… – Continue reading
EU leaders have not yet made a clear choice about how to make sure digital companies pay their fair share of taxes. At an EU summit in Brussels on Thursday (19 October), they adopted a text that balances the wishes of two groups of countries – and can be interpreted… – Continue reading
BRATISLAVA, Oct.18 (Xinhua) — International information exchange system could help fight tax evasion, said President of Slovak Financial Administration Frantisek Imrecze at a press conference here on Wednesday. According to Imrecze, the information exchange system has been available to the Slovak Financial Administration since Sept. 30, the Slovak tax office… – Continue reading
ZURICH (Reuters) – Switzerland said on Wednesday it would start sharing information on the activities of multinationals in its territory with other countries in 2020, joining an international push to fight tax evasion. The new measures will force about 200 large companies in the low-tax haven to prepare country-by-country reports… – Continue reading
NZ’s IRD a global leader in shift to digital, unobtrusive tax administration, Ferguson says Oct. 18 (BusinessDesk) – The Inland Revenue Department is leading the charge in a global shift to digitally-based tax administration that’s unobtrusive and easy to use, says commissioner Naomi Ferguson. The New Zealand tax department is… – Continue reading
OECD Secretary-General Angel Gurria has called for a collective effort on the design of temporary, short-term measures to tackle the international tax challenges of the digital economy. Speaking at the Group of Twenty (G-20) Finance Ministers and Central Bank Governors meeting held in Washington on October 13, Gurria said: “There… – Continue reading
Republic has implemented all four agreed standards under OECD’s tax/profit project An international body overseeing global tax practices has said that Singapore’s tax incentives meet the international standards on countering corporate tax avoidance. The Forum on Harmful Tax Practices (FHTP) said in a report yesterday that it had reviewed 164… – Continue reading
Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27… – Continue reading
Imagine a world where Indian tax authorities can look at a document to see whether a multinational company is paying taxes commensurate to the profit it generates in India. The genesis of such a world lies in OECD’s Base Erosion and Profit Shifting Project. Back in 2015, the Organisation for… – Continue reading
THE Attorney General yesterday lamented that “riding behind our competitors” had caused “incalculable” damage to the financial services industry, accusing the former government of failing to act on tax information exchange changes. Carl Bethel QC, addressing the Senate, said the Christie administration had “done nothing’ for three years in relation… – Continue reading
The US IRS announced this week on its website that the US has entered into a bilateral competent authority agreement with Greece to exchange country-by-country reports on multinationals. The agreement between the IRS and the Greek Independent Authority for Public Revenue, signed September 27, puts into effect a 2015 deal… – Continue reading
The Irish Government has published an updated version of its International Tax Strategy, which provides an overview of the steps taken to meet international standards and sets out the Government’s position on global reform efforts. In his foreword to the Tax Strategy paper, Finance Minister Paschal Donohoe said: “In Ireland… – Continue reading
The Irish government is inviting businesses and practitioners to provide feedback on its plans to update its international tax strategy, including how Ireland should incorporate the OECD’s transfer pricing guidelines into national law and implement the European Union’s anti-tax avoidance rules. The consultation, which runs until the end of January… – Continue reading
New Delhi [India], Oct.6 (ANI): In keeping with India’s commitment to implement recommendations of 2015 Final Report on Action 13, titled “Transfer Pricing Documentation and Country-by-Country Reporting”, the Department of Income Tax has invited comments from stakeholders and the general public. It has said that these comments and suggestions on… – Continue reading
EU nations led by France and Italy reinforced the need for an “equalization tax” or turnover tax on large internet companies such as Facebook Inc. and Amazon.com Inc., and suggested they would use special legislative procedures to impose one in the event all 28 EU-member countries don’t back the levy…. – Continue reading
C&AG report reveals significant variations in average tax rate paid by top 100 companies Some 13 of Ireland’s top 100 companies pay an effective rate of tax of just 1 per cent, the latest Comptroller and Auditor General (C&AG) report has found. The low rate, which is significantly below the… – Continue reading
On 29 August 2017, Greenland officially joined the Global Forum on Transparency and Exchange of Information for Tax Purposes. Greenland thereby declared its commitment to implement both the international standard of exchange of information on request and the standard on automatic exchange of financial account information. On 8 February 2017… – Continue reading
If you live in Nigeria and you have a foreign bank account; you should read this.If things go as planned, the FIRS will soon have access to information on the money and other financial investments that you have in your foreign bank account. This will happen when the Common Reporting… – Continue reading
The Inter-American Center of Tax Administration (CIAT) has released a new statement summarizing the feedback from Latin American and Caribbean countries from ongoing discussions on countering base erosion and profit shifting. CIAT said it and a number of regional and international organizations have brought together policymakers from countries in the… – Continue reading
The automatic exchange of tax information (AIE) between countries is generally seen as an effective way of cracking down on tax cheats. But what if a country uses the data to politically oppress its citizens? It’s a burning issue facing Swiss lawmakers. This week, Swiss parliament will begin a debate… – Continue reading
As of August 2017, 102 international Jurisdictions are committed to the implementation timelines of the Common Reporting Standard (CRS). There are 49 Jurisdictions that are committed to the first exchange during 2017 and 53 Jurisdictions for 2018. The OECD is taking extra precautions to ensure that reportable financial information regarding… – Continue reading
KARACHI: The tax authorities have kicked off a planned program under which they share foreign individuals’ financial-account information with the member countries of the Organization for Economic Cooperation and Development (OECD), sources said on Saturday/ The Federal Board of Revenue (FBR), issued a notification regarding the schedule for exchange of… – Continue reading
Bermuda has become the first overseas territory to be awarded whitelist status by France. David Burt, the Premier, told MPs the development underlined the Ministry of Finance’s efforts to support international co-operation on tax matters and financial transparency. He added that he will attend key meetings in Paris and Brussels… – Continue reading
The World Bank has released French and Spanish translations of its Toolkit on the taxation of offshore indirect transfers and extended the deadline for feedback to October 20. The tax treatment of “offshore indirect transfers” (OITs) – in essence, the sale of an entity owning an asset located in one… – Continue reading
Appropriate Use of Country-by-Country Reports The OECD has now published Guidance (available here) on the appropriate use of Country-by-Country Reports (‘CbCRs’) by national tax authorities. This is in response to some valid MNE concerns that tax authorities may misuse CbCRs. “Appropriate use” is clarified as being for (i) high-level transfer… – Continue reading
Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country… – Continue reading
The OECD has taken issue with the Estonian Government’s plans to reduce the rate of tax on distributed dividends for established companies, warning that the measure could complicate the tax system and discriminate against small firms. Under recently enacted legislation, tax on distributed dividends will be reduced from 20 percent… – Continue reading
Ireland’s Minister for Finance (the “Minister”) welcomed the results of the independent review of Ireland’s corporation tax regime (the “Review”) issued on 12 September 2017: “I welcome the emphasis given in the Review to the importance of certainty, which is core to our corporate tax offering. Our 12.5% corporation tax… – Continue reading
JAKARTA — Indonesia’s government has issued new regulations aimed at tracing and taxing the wealth of taxpayers who were not pardoned in the nine-month tax amnesty that ended in March. Around 972,000 taxpayers joined the amnesty programme and declared assets worth a total of 4,881 trillion rupiah (272 billion pounds)…. – Continue reading
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… – Continue reading
Changes in international tax laws spurred by the OECD’s BEPS project pose challenges for finance chiefs, but also offer some opportunities. The OECD’s base erosion and profit shifting (BEPS) project, with an overall goal of reducing global loss of tax revenues due to double non-taxation, has created the need for… – Continue reading
With corporate tax reform still very much on the table, advocacy group Alliance for Competitive Taxation (ACT) has weighed in with a reform plan that it deems internationally competitive and pro-growth, and capable of driving transformational change in the U.S. economy. ACT doesn’t define its member businesses but says it… – Continue reading
Greece is defying the prevalent trend among the world’s industrialized nations for reducing tax rates in order to boost investment and competitiveness, a report published on Wednesday by the Organization for Economic Cooperation and Development (OECD) has shown. According to the report, in contrast to the majority of… – Continue reading
Brunei has become the 113rd signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, signing the pact at the OECD headquarters on September 12. The Convention is touted by the OECD as “the most powerful instrument for international tax cooperation.” It provides for all forms of administrative… – Continue reading
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… – Continue reading
The four biggest economies in the Eurozone – Germany, France, Italy, and Spain — demand an end to the erosion of their tax base by means of incorporation in states that facilitate tax avoidance. According to the Financial Times, Bruno Le Maire, Wolfgang Schaeuble, Pier-Carlo Padoan, and Luis de Guindos,… – Continue reading
Argentina is reportedly considering shifting the burden of tax towards consumption, to bring the country’s corporate tax rate down to a competitive level. Specific measures are expected to be tabled before lawmakers soon. It is anticipated that there could be a 10 percent cut to the corporate income tax rate,… – Continue reading
President Donald J. Trump is working to reform the tax system so that Americans are treated fairly and can keep more of their hard-earned money, and companies can bring jobs back to the United States. According to a news release from the administration, Trump will jumpstart America’s economic engine by… – Continue reading
The government said Wednesday that it will toughen its stance against tax evasion by multinational firms by adopting a global agreement in the country’s legal system within the year. In the mid-to-long term tax policy plan announced Wednesday, the finance ministry said that it would submit bills to enact “OECD… – Continue reading
Brazil’s unique international tax rules present a significant challenge for both the OECD and Brazil, as the South American country seeks to join the international organization. However, the challenges aren’t insurmountable. The push for Brazil to join the Organization for Economic Cooperation and Development “is a little bit rushed,” Sergio… – Continue reading
MEDIUM and large businesses with multinational ties will soon have to start supplying the South African Revenue Service (SARS) with more detailed reports of their relationships and transactions with connected entities residing in other countries. SARS has beefed up its Transfer Pricing Division and is now actively involved in the… – Continue reading
MULTINATIONAL corporations (MNCs) in Malaysia will soon be seeing more tax law changes coming their way as the authorities get down to tackling base erosion and profit shifting (BEPS). This follows efforts by the Organisation for Economic Co-operation and Development (OECD), approved by G20 leaders, to formulate a 15-step action… – Continue reading
