McDonald’s Australia was able to more than halve its tax bill last year after routing payments via the low-tax nation of Singapore. Each year McDonald’s reduces its profit, and thus its local tax bill, by paying McDonald’s Asia Pacific based in Singapore, and registered in Delaware, a “service fee” amounting… – Continue reading
The announcement of another tax and exchange control amnesty in this year’s budget is keenly awaited by some South African taxpayers. The looming implementation of the Common Reporting Standard for the automatic exchange of financial information between more than a hundred countries seems to be fueling the desire for another… – Continue reading
The U.S. Internal Revenue Service on Tuesday announced that, starting February 16, its Advance Pricing and Mutual Agreement office will begin accepting requests for bilateral advance pricing agreements between the U.S. and India. This marks a big step forward to ensure tax certainty between the two countries, according to experts…. – Continue reading
JOHANNESBURG – A data sharing agreement signed by 31 countries – including South Africa – in a bid to enhance transparency by multinational enterprises, is unlikely to have an immediate impact on mining companies. Through the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reporting, signed by members of… – Continue reading
The debate about corporation tax intensifies. Is the tax on profit no longer viable now that the global nature of modern business is making it ever harder for individual governments to enforce? Director asks two business leaders, has globalisation made corporation tax redundant? Yes, says Stephen Herring, head of taxation… – Continue reading
Mauritius will start automatic exchange of tax information with other nations only from September 2018, as it has postponed by a year implementation of global common reporting standard on tax matters. The delay could impact Indian authorities’ efforts to gather more tax-related information from Mauritius, which is allegedly being used… – Continue reading
In our previous columns, we discussed the final reports of the Organisation for Economic Co-operation and Development (OECD) on the different action plans to address Base Erosion and Profit Shifting (BEPS). We will now focus on Action 14, which reflects the commitment of participating countries to implement substantial changes in… – Continue reading
Radical changes to business taxation may be necessary to reduce large multinationals’ ability to avoid levies, a respected economic think tank has indicated. In the wake of the row over Google’s deal with HM Revenue and Customs, the Institute for Fiscal Studies (IFS) suggested a shake-up of the corporation tax… – Continue reading
The EU’s anti-base erosion and profit shifting (BEPS) proposals could have consequences for captives in Europe, as politicians pinpoint reinsurance arrangements as a means of unfair tax avoidance. The European Commission introduced a range of anti-tax avoidance proposals on 28 January, following the release of the Organisation for Economic Co-operation… – Continue reading
Despite the anticipated tsunami of tax disputes generated by underlying tensions in international taxation, there is reason for hope that appropriate means are being developed to address them efficiently and effectively. Multinational enterprises (MNEs) should be addressing their existing international taxation planning structures in light of coming changes in international… – Continue reading
The European Parliamentary Research Service has estimated that corporate tax-dodging costs the EU between $54.5 billion and $76.4 billion a year. The European Commission has proposed a package of measures to clamp down on corporate tax avoiders that would close a loophole companies have used to shift profits to low-tax… – Continue reading
Upcoming changes to the Exchange of Information framework hints at future adoption of the Organisation for Economic Co-operation and Development’s Common Reporting Standards. The crux of Singapore’s Income Tax (Amendment) Bill 2016, which some think may signal a new chapter in this sphere, may be summarised as follows: The minister… – Continue reading
Those who have been hiding their income or wealth overseas had better think again, as Korea will soon be exchanging financial information with multiple countries, including tax havens. They are advised to voluntarily report it to the government before the end of March to be given a grace period, said… – Continue reading
The Italian Patent Box regime largely complies with the OECD recommendations to prevent base erosion and profit shifting. Its non-compliant features offer a brief window of opportunity for companies able to take swift advantage of its wide range of qualifying intangible assets. Many countries have implemented specific IP regimes through… – Continue reading
Australia is one of 31 countries to sign an agreement in Paris to confidentially share tax information on multinational companies in a bid to stamp out tax avoidance. The deal comes as Apple has taken advantage of accounting rules in its local business that could allow it to pay virtually… – Continue reading
Today’s proposals aim for a coordinated EU wide response to corporate tax avoidance, following global standards developed by the OECD last autumn. New rules are needed to align the tax laws in all 28 EU countries in order to fight aggressive tax practices by large companies efficiently and effectively. The… – Continue reading
2015 has officially come to an end. Amidst the ending celebrations, packing away of decorations, and last spoonful of dessert, many of us are putting together our work plans and resolutions for 2016. And looking back at last years’ list, there remains one capitalised, un-crossed-off item: BEPS Perhaps your organisation… – Continue reading
Can tax treaty provisions override domestic law?In our last article we defined double taxation as an exposure to tax more than once on the same profit or income. We also highlighted the two types of double taxation i.e. economic double taxation and juridical double taxation and also noted that a… – Continue reading
x The government plans to exchange financial information on multinational firms doing business here with members of the OECD and G20 countries in order to make them pay appropriate taxes to countries where profits are generated, officials said Thursday. The Ministry of Strategy and Finance said that it will follow… – Continue reading
BRUSSELS (Alliance News) – The EU stepped up the fight against corporate tax avoidance Thursday, unveiling proposals including an EU-wide blacklist of international tax havens, as part of a wider clampdown on firms using loopholes to reduce their tax bills. The EU’s executive estimates that member states are deprived of… – Continue reading
India and Armenia on Wednesday signed a protocol to amend the existing Double Taxation Avoidance Convention between the two countries. “The Protocol amends the Article on Exchange of Information for tax purposes to bring it in line with the updated provisions in the OECD Model,” said a Finance Ministry release…. – Continue reading
Moving money out of the usual offshore secrecy havens and into the U.S. is a brisk new business. Last September, at a law firm overlooking San Francisco Bay, Andrew Penney, a managing director at Rothschild & Co., gave a talk on how the world’s wealthy elite can avoid paying taxes…. – Continue reading
The South African Revenue Service (Sars) has published additional record-keeping requirements for large multi-national companies which they will have to comply with in future. Many companies have already included some of the required information in their transfer pricing documentation and on their annual tax returns, but there seems to be… – Continue reading
The Australian Taxation Office has stepped up investigations into Australians with Swiss bank accounts, pursuing some individual debts worth more than $100 million. Figures obtained by The Australian also show that in the past 12 months the ATO has handed the details of more than 30,000 ¬financial accounts to the… – Continue reading
Australia must not be blown off course from getting a company tax rate closer to 20 per cent. Corporate tax transparency figures released in December by the Australian Taxation Office should not slow momentum. For the first time, the ATO reported the tax affairs of companies with total incomes of… – Continue reading
In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading
Despite EU intentions to crack down on tax avoidance, the European Commission’s Anti-Tax Avoidance Package does not do what it says on the tin, warns Oxfam, and developing countries will feel the EU’s failure most. The package comes a week after the international NGO revealed that just 62 people own… – Continue reading
NEW DELHI, JANUARY 26:Ministers and top tax officials from more than 30 countries including India will sign an international agreement on Wednesday to significantly advance the fight against corporate tax avoidance. This agreement – Multilateral Competent Authority Agreement (MCAA) – will be signed at the OECD in Paris, sources said…. – Continue reading
Ireland will be forced to ban many of the tax advantages it offers multinationals under proposals to be published by the European Commission tomorrow. This is the first step in an effort to have all EU countries introduce similar tax rules to prevent companies in the 28 member states avoiding… – Continue reading
Directive follows a series of high-profile tax cases involving Google, Apple and others. Rampant corporate tax dodging and sweetheart deals that cheat governments and skew markets, have prompted the European Commission to unveil a new directive Thursday. The proposed legislation follows a quick succession of tax rulings, settlements and investigations… – Continue reading
NEW DELHI, JANUARY 26:A majority of Indian multinationals see the implementation of base erosion and profit shifting (BEPS) project of the Organisation for Economic Cooperation and Development leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting… – Continue reading
NEW DELHI, JAN 25: A majority of Indian multinationals see the implementation of OECD’s BEPS project leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting given that one of the objectives of OECD’s Action Plan on Base… – Continue reading
On 5th October 2015, the OECD released its final reports setting out the action plan on Base Erosion and Profit Shifting (BEPS) project, thus concluding the two year project which started at the behest of G20 countries in 2013. The reports are aimed at suggesting the measures to reform the… – Continue reading
The Gulf countries’ proposed 5% value added tax (VAT) may translate as more than a 10% hit on net income, unless tax efficiencies are improved, according to Ernst and Young (EY). “A 5% rate may not sound like a lot, but if it ends up as an additional cost on… – Continue reading
DAVOS, Switzerland—Google said Friday that it has struck a deal with U.K. authorities that will settle a tax dispute and boost its corporate taxes in Britain, part of a broader effort by European governments to wring more out of big firms in the tech sector. As part of the settlement,… – Continue reading
India to change laws in Union Budget to make country-by-country reporting mandatory for Indian multinationals New Delhi: India will change laws in the upcoming budget to make country-by-country reporting mandatory for Indian multinationals to ensure they follow so-called base erosion and profit shifting (BEPS) guidelines. The norms were announced in… – Continue reading
Multinational companies are facing severe constraints on their ability to avoid taxes on their activities in Europe as regulators seek to close loopholes laid bare by the LuxLeaks scandal Pierre Moscovici, the EU’s tax policy chief, will set out plans next week to curb practices such as using debt interest… – Continue reading
The Mauritius Revenue Authority (MRA) has confirmed the first exchanges of information under the Common Reporting Standard will now take place from September 2018, rather than September 2017. The OECD’s CRS, the new global standard for automatic exchange of information for tax purposes, obliges all participating countries and jurisdictions to… – Continue reading
Tax dodging by the super-rich is one of the main drivers of global income inequality and must be sharply curtailed, according to a new report from the global nonprofit Oxfam. Citing research by Berkeley economist Gabriel Zucman — a protégé of Thomas Piketty, author of the global bestseller on inequality,… – Continue reading
FOCUS: Major infrastructure projects and other purely commercial transactions could suffer collateral damage from proposals to reform the international tax system and prevent avoidance by multinationals. Rising tax costs could put additional strain on the viability of key projects. Infrastructure projects are capital intensive and often have a high level… – Continue reading
India’s biggest source of FDI is India itself, money departing on a short holiday to a tax haven and then routed back as FDI. Will the government muster up the political will to clamp down on the tax-allergic business elite? This could be a bumper year for the ever-lucrative tax… – Continue reading
Budget to implement some of OECD’s standards on profit-shifting NEW DELHI, JANUARY 21:Large multinational enterprises (MNEs) may be required post-Budget to furnish to Indian tax authorities information on their global incomes and taxes. This move — a fallout of India agreeing to OECD’s Action Plan on Base Erosion and Profit… – Continue reading
As from 1 January 2016, new rules have become effective in the Netherlands that require multinational enterprises (“MNEs“) to comply with new transfer pricing documentation requirements, including the obligation to prepare a Country-by-Country Report (“CbC Report“), a Master File and a Local File. These rules essentially implement Action 13 of… – Continue reading
Budget to implement some of OECD’s standards on profit-shifting NEW DELHI, JANUARY 21: Large multinational enterprises (MNEs) may be required post-Budget to furnish to Indian tax authorities information on their global incomes and taxes. This move — a fallout of India agreeing to OECD’s Action Plan on Base Erosion and… – Continue reading
The Yomiuri Shimbun Four international organizations will join forces to devise unified global tax rules aimed at preventing tax evasion by multinational companies. The four entities involved are the Organization for Economic Cooperation and Development, the United Nations, the International Monetary Fund and the World Bank. The OECD — whose… – Continue reading
MUMBAI: In what could lead to an increase in domestic tax liabilities of many Indian conglomerates and multinationals, the government is set to introduce a framework for Base Erosion and Profit Shifting (BEPS), a global agreement to check tax avoidance by multinationals, in the upcoming Budget. Industry sources expect the… – Continue reading
The Financial Services Council (FSC) is calling for the company tax rate to be cut by eight percentage points to 22 per cent in order to boost growth, investment and employment. The FSC has released a tax reform package, which it said would turn around Australia’s sagging competitiveness and flat… – Continue reading
On 1st January 2016, an amendment to the Mutual Legal Assistance (Tax Matters) Act, 2003 came into force which implements the Organisation for Economic Co-Operating and Development (OECD) Common Reporting Standard for the exchange of tax information (CRS) in the British Virgin Islands (BVI). Globally this means that participating jurisdictions… – Continue reading
The change in definition of an Indian resident company under the Income-Tax Act—from one whose affairs are wholly controlled and managed in India to one whose Place of Effective Management (PoEM) is in India—and the subsequent draft guidelines are giving anxious moments to votaries of simplifying the investment climate in… – Continue reading
Plans to restrict the generous tax treatment of interest costs — a key aspect of Britain’s business-friendly taxation regime — are unnecessary and potentially damaging, companies have told the Treasury. Professional bodies and business groups are voicing fears about the restrictions that are set to be introduced as part of… – Continue reading
