Category: OECD

British Virgin Islands / Cayman Islands / Common Reporting Standard / Forms / Guernsey / Investments / Ireland / Jersey / OECD / Residency / United Kingdom

Additional OECD CRS self-certifications required from investors subscribing to Cayman Islands (and other non-U.S.) investment funds on or after January 1, 2016

Posted On: December 17, 2015

The Cayman Islands (along with the United Kingdom, Ireland, Jersey, Guernsey, the British Virgin Islands and over 70 other countries) has committed to implementing the OECD Common Reporting Standard (“CRS”), which will require investment funds to collect tax identification and tax residency information from all new subscribers and transferees (including… – Continue reading

Asia / Australia / Cambodia / China / Europe / G20 / India / Indonesia / Japan / Laos / Legislation / Malaysia / OECD / Philippines / Singapore / South Korea / Thailand / Transfer pricing

Transfer pricing law in Thailand and the BEPS initiative

Posted On: December 17, 2015

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

Base Erosion & Profit Shifting / Capital gains / Double Tax Treaty / Double Taxation / EU / Intellectual Property / Investments / Loans / Luxembourg / OECD / Offshore Tax Evasion / Parent-Subsidiary Directive / Permanent establishment / Residence / Royalties / Tax Amnesty / Tax Credit / Tax Planning

Luxembourg – Main New 2016 Tax Measures At A Glance

Posted On: December 17, 2015

IP regime  To comply with the OECD’s BEPS reports and more specifically its action plan n° 5 regarding harmful tax practices, the Luxembourg intellectual property (“IP“) regime under article 50bis of the Luxembourg income tax law (“ITL“) will be repealed as from 1 July 2016. As such, the Luxembourg 80%… – Continue reading

Asia / Base Erosion & Profit Shifting / Caribbean / China / Europe / OECD

China joins OECD tax data compact

Posted On: December 17, 2015

China has become the 77th party to an OECD agreement enabling the automatic annual exchange of tax-related information. The country signed up to the Multilateral Competent Authority Agreement (MCAA) yesterday, which specifies which information will be exchanged and when, and renewed a co-operation agreement between the OECD and the Chinese… – Continue reading

Advance Pricing Agreement / Automatic Exchange of Information / Base Erosion & Profit Shifting / EU / G20 / OECD / Transfer pricing

Tax Update: Tax Ruling Transparency in the EU – What You Need to Know

Posted On: December 17, 2015

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

Bangladesh / Corruption / Double Taxation / India / Investments / Legislation / OECD / Pakistan / Tax Laws

‘Tax rules worsen business climate’

Posted On: December 17, 2015

ISLAMABAD: The World Bank says tax regulations in Pakistan are frequently altered, and unpredictable tax rules worsen the business climate and may deter potential investment. The report “Towards a more friendly tax regime: Key challenges in South Asia,” points out that South Asia’s tax regulations are complex and difficult to… – Continue reading

Beneficial Ownership / Cayman Islands / Citizenship / Common Reporting Standard / FATCA / IGA / Ireland / Luxembourg / OECD / Offshore Tax Evasion / Residency / USA

Worldwide: Global FATCA: Let’s Do It Again

Posted On: December 17, 2015

Fifty-three jurisdictions have agreed to automatic exchange of tax information beginning in 2017, under the OECD’s Common Reporting Standard. Over 40 others have committed to exchange information by 2018. Another wave of global tax information is about to take place, and financial institutions everywhere are in a race to prepare… – Continue reading

Andorra / Argentina / Austria / Automatic Exchange of Information / Canada / Capital gains / Cyprus / Dividends / Dominican Republic / Double Taxation / EU / Finland / Guernsey / India / Isle of Man / Jersey / Monaco / Nigeria / OECD / Oman / Qatar / Real Estate / Royalties / Senegal / Spain / United Kingdom / USA / Uzbekistan

Spain and Finland sign new treaty to avoid double taxation and to fight tax fraud

Posted On: December 16, 2015

Given that the latest treaty was signed on 15 November 1967, the two countries felt it was appropriate to revise it in full. The new treaty, signed on Tuesday by the Spanish Ambassador to Finland, María Jesús Figa, and the Finnish Minister for Finance, Alexander Stubb, seeks to enable tax… – Continue reading

Cayman Islands / Common Reporting Standard / FATCA / OECD

Cayman Islands: The Cayman Islands Implements The Common Reporting Standard Effective 1 January 2016

Posted On: December 16, 2015

On 7 December 2015 the Cayman Islands Tax Information Authority (the “TIA”) published a list of 95 participating jurisdictions (see Schedule below) pursuant to The Tax Information Authority (International Tax Compliance) (Common Reporting Standard) Regulations, 2015 (the “Regulations”) and the Cayman Islands FATCA/CRS Working Group (the “Working Group”) distributed self-certification… – Continue reading

Canada / Common Reporting Standard / EU / FATCA / IGA / Legislation / OECD / Privacy / Residence / Tax treaties / Trustee / United Kingdom / USA

The end of financial privacy?

Posted On: December 16, 2015

Over 90 jurisdictions have committed to the OECD’s Common Reporting Standard (CRS), creating comprehensive global automatic information exchange for financial assets and the entities through which such assets may be held. Over 70 jurisdictions have signed the OECD’s Multilateral Competent Authority Agreement, which implements the CRS. The CRS is scheduled… – Continue reading

Australia / Automatic Exchange of Information / Base Erosion & Profit Shifting / China / G20 / OECD / Offshore Tax Evasion / Turkey

China takes important step to boost international co-operation against tax evasion

Posted On: December 16, 2015

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

Austria / Automatic Exchange of Information / Common Reporting Standard / EU / FATCA / G20 / IGA / Ireland / OECD

Ireland: Common Reporting Standard (CRS) Update

Posted On: December 16, 2015

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

Automatic Exchange of Information / Common Reporting Standard / EU / Legislation / Luxembourg / OECD

Luxembourg: CRS implementing legislation moves forward

Posted On: December 16, 2015

The Luxembourg Parliament unanimously passed legislation that would transpose into domestic law an EU directive concerning the automatic exchange of information in the field of taxation (a directive known as “DAC 2”). The DAC 2 provides that EU Member States are to require financial institutions to implement reporting and due… – Continue reading

Base Erosion & Profit Shifting / Legislation / Mexico / OECD / Transfer pricing

Mexico Enacts CbC Reporting Regime

Posted On: December 16, 2015

Mexico has recently gazetted new transfer pricing documentation requirements, which will be effective from the 2016 tax year. The legislation was submitted to Congress by the Government on September 8, 2015, and published in the Official Gazette at the end of November. It will introduce the country-by-country (CbC) reporting framework… – Continue reading

Base Erosion & Profit Shifting / EU / OECD / Tax competition / Tax Laws / Tax Planning

Action Plan for Fair and Efficient Corporation Taxation in the EU

Posted On: December 16, 2015

Re-launching the Common Consolidated Corporate Tax Basis (CCCTB) Corporate taxation in the EU needs to be fundamentally reformed. Today’s corporate tax systems in EU Member States were conceived in the 1930s, when cross-border trade was more limited, business models were simpler and products were tangible. But as business evolves, so… – Continue reading

Base Erosion & Profit Shifting / EU / Europe / France / Germany / Intellectual Property / Investments / Ireland / Italy / OECD / Spain / Sweden

Multinational moves could prompt major losses in corporate tax

Posted On: December 16, 2015

Action on tax avoidance could see €600m go from the pharma sector, says report International moves on multinational tax could threaten Ireland, with a potential annual loss of corporate tax revenue of €600 million or more from the pharma sector alone, according to a new report from Chartered Accountants Ireland…. – Continue reading

Armenia / Bangladesh / Base Erosion & Profit Shifting / Capital gains / Double Taxation / DTA / Finland / G20 / Greece / India / Ireland / Italy / Japan / Kazakhstan / Korea / Mauritius / OECD / Residence / Tax Information Exchange Agreements

Double taxation avoidance

Posted On: December 16, 2015

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

Austria / Belgium / Bulgaria / Czech Republic / Denmark / Double Taxation / Estonia / EU / Europe / Finland / France / Germany / Hungary / Intellectual Property / Ireland / Italy / Luxembourg / Netherlands / OECD / Permanent establishment / Poland / Portugal / Research and Development (R&D) / Romania / Royalties / Slovakia / Spain / State Aid / Sweden / Tax competition / Tax Credit / USA

IP BOX: Italian and European Legal Framework

Posted On: December 16, 2015

On 22 December 2014, the Italian Parliament approved the Budget for 2015.40 Among other measures, the Law introduces the possibility of an exemption from corporate income tax (IRES, generally levied at 27,5%) and local tax (IRAP, generally levied at 3,9%) on income derived from qualifying intangible assets (such as patents,… – Continue reading

Europe / Luxembourg / Malta / OECD / Tax competition

EP votes in favour of stopping corporate tax avoidance; Malta could lose competitive edge

Posted On: December 16, 2015

A vote taken in the European Parliament could effectively rob Malta of its ability to attract multinational companies and their millions of Euros in taxation revenue. A vast majority of MEPs, spanning across all political groups showed their support for a resolution, prepared in Parliament’s Economic and Monetary Affairs Committee…. – Continue reading

Angola / Brazil / Corruption / Double Taxation / EU / Japan / Latvia / Moldova / OECD / Portugal

Latvian president calls for double taxation treaty with Japan

Posted On: December 16, 2015

Latvian President Raimonds Vejonis on December 15th accepted the credentials of the Japanese Ambassador to Latvia, Mariko Fujii, and noted an increase in Latvia-Japan trade recently but said there was still room for growth in economic cooperation, the Latvian president’s press service reported LETA. He said that a treaty for… – Continue reading

Automatic Exchange of Information / Base Erosion & Profit Shifting / Belgium / EU / G20 / Legislation / OECD / Permanent establishment / Tax treaties / Transfer pricing

Belgian Minister of Finance sheds light on implementation of BEPS related measures

Posted On: December 15, 2015

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

Base Erosion & Profit Shifting / KPMG / Legislation / Mexico / OECD / Permanent establishment / Residency / Shares / Transfer pricing

Mexico: Reminder of expanded transfer pricing disclosures for 2016

Posted On: December 15, 2015

Provisions under new article 76A of Mexico’s tax law reflect certain items of the OECD’s base erosion and profit shifting (BEPS) project—in particular expanded transfer pricing disclosure requirements that will apply for the 2016 tax year. Background The Mexican government’s 2016 federal budget, presented 8 September 2015, included proposals for… – Continue reading

Base Erosion & Profit Shifting / Capital gains / Dividends / EU / Gaar / Hybrids / Intellectual Property / Investments / Legislation / Loans / OECD / Offshore Investments / Research and Development (R&D) / Shares / Tax Credit / Tax Planning / Transfer pricing / Trustee / United Kingdom

UK releases Finance Bill clauses and consultation documents

Posted On: December 15, 2015

Executive summary On 9 December 2015, the UK released draft clauses for Finance Bill 2016 as well as consultation documents. The key items released include: A new requirement for large businesses to publish their tax strategies as they relate to or affect UK taxation. This sits alongside new ‘special measures’… – Continue reading

Base Erosion & Profit Shifting / OECD / Permanent establishment

BEPS Action Point 7 – Amendments to article 5 of the OECD Model Tax Convention

Posted On: December 15, 2015

On 5 October 2015, the OECD published its final report on Action Point 7 of the BEPS initiative (Preventing the Artificial Avoidance of Permanent Establishment Status), which entails a significant change to the current definition of permanent establishment (PE) in article 5 of the OECD Model Tax Convention. The purpose… – Continue reading

Caribbean / OECD / St. Kitts & Nevis / Tax Information Exchange Agreements / Tax treaties

St Kitts And Nevis To Improve Tax Info Exchange

Posted On: December 15, 2015

Caribbean territory Saint Kitts and Nevis has proposed legislative changes to improve its ability to exchange information with treaty partners in tax matters. The territory’s Prime Minister, Timothy Harris, explained that the changes have been prompted by an increasing number of requests from treaty partners, which he attributed to a… – Continue reading

Automatic Exchange of Information / Dividends / EU / Europe / Fees / Legislation / OECD / Tax Laws

European Commission adopts new rules to help EU tax authorities exchange information

Posted On: December 15, 2015

On December 15, 2015 the European Commission issued a media release announcing that on that same date it adopted new rules to make it easier for EU Member States’ tax authorities to exchange financial information so that they can ensure full tax transparency and cooperation. According to the media release… – Continue reading

Automatic Exchange of Information / British Virgin Islands / Common Reporting Standard / Directors / FATCA / FATF / Fees / Legislation / OECD / Offshore Companies

British Virgin Islands: Proposed Amendments To BVI Business Companies Legislation

Posted On: December 15, 2015

The BVI Business Companies Act 2004 (“BCA“) is shortly due to be amended by the BVI Business Companies (Amendment) Act 2015 (the “Amendment Act”). As well as keeping the British Virgin Islands (“BVI“) corporate regime at the forefront of compliance with international standards, the Amendment Act is intended to provide… – Continue reading

Directors / Double Taxation / Finland / Nokian Tyres / OECD / Russia / Transfer pricing

Nokian Tyres received EUR 87 million additional payable tax in Finland regarding years 2007-2010

Posted On: December 15, 2015

the company will make a complaint against the decision Nokian Tyres plc (HEX:NRE1V) has received a renewed reassessment decision from the Tax Administration, according to which the Company is obliged to pay EUR 87 million additional taxes with punitive tax increases and interests concerning tax years 2007-2010. Payment must be… – Continue reading

Dividends / Double Tax Treaty / Double Taxation / EU / Legislation / Malta / OECD / Permanent establishment / Residence / Royalties / Tax treaties

Malta: The Tax Challenges Of The Digital Economy – Article 3

Posted On: December 15, 2015

Main principles of Direct Taxation – Double Tax Treaties In our third article in a series of articles on the tax challenges of the digital economy, we shall be providing you hereunder with a brief overview of the principles of direct taxation, with a focus primarily on the taxation of… – Continue reading

Latvia / Legislation / OECD / Tax Laws / Transfer pricing

Transfer pricing findings from the court house

Posted On: December 15, 2015

Dear clients and cooperation partners, This newsflash will tell you about findings reflected in court judgements with regard to application of resale price method, and in particular – contradictions in calculation of arm’s length profit level. Recent transfer pricing judgements in Latvia lead to increased controversy in application of resale… – Continue reading

Amazon / Base Erosion & Profit Shifting / Double Taxation / Facebook / Germany / Google / Luxembourg / OECD / Permanent establishment / Profit Shifting / Starbucks / Tax Planning / Transfer pricing / USA

BEPS also applies to medium-sized businesses

Posted On: December 14, 2015

Stricter Tax and documentation requirements for foreign transactions “Amazon, Facebook, Google and Starbucks pay little taxes …” or “Luxembourg attracts international corporations” – headlines like these have 62 states and the OECD called into action. The result was “base erosion and profit shifting” BEPS shortly. Even the German SME sector… – Continue reading

Apple / Double Taxation / EU / Europe / Gaar / IGA / IMF / Ireland / Legislation / Luxembourg / Michael Noonan / OECD / Royalties / State Aid / Tax competition / Tax Planning / Transfer pricing / United Kingdom

Ireland regains its swagger in the tax arena

Posted On: December 14, 2015

Something unusual is happening with the Irish corporation tax in 2015 — so unusual that Ireland’s top tax man felt obliged to write to the parliament to explain what is going on. But the explanation left a lot to be desired. According to government data, Ireland received 57.7 percent more… – Continue reading

Automatic Exchange of Information / Bermuda / British Virgin Islands / Cayman Islands / Common Reporting Standard / OECD / Offshore Investments / Residence / USA

Common Reporting Standard Enters Into Effect for Investment Funds in Early Adopter Jurisdictions

Posted On: December 14, 2015

Many jurisdictions have agreed to implement the Organisation for Economic Co-operation and Development’s multilateral system of automatic exchange of information called the “Common Reporting Standard” (CRS).  In furtherance of its objectives, the CRS imposes a variety of diligence and reporting requirements on “financial institutions,” which includes many master funds, offshore… – Continue reading

Base Erosion & Profit Shifting / Corporates / Double Taxation / EU / OECD / Tax Planning

European Union: EU Combats International Tax Planning: The Amended Parent Subsidiary Directive

Posted On: December 14, 2015

You have probably read about the OECD’s comprehensive base erosion and profit shifting (or BEPS) action plan aimed at tackling undesirable international tax planning by corporates. In recent years, the EU, particularly the European Commission, has put substantial effort into accelerating BEPS-like measures in an EU context. A striking example… – Continue reading

Beneficial Ownership / Cyprus / Dividends / Double Tax Treaty / Double Taxation / OECD / Royalties / Shares / Switzerland

Cyprus: Double Tax Treaty Between Cyprus And Swiss Confederation

Posted On: December 14, 2015

On 15th October 2015, the Double Tax Treaty between the Republic of Cyprus and Swiss Confederation had entered into force (the “Treaty“). The said Treaty is based on the OECD Model Convention on the Avoidance of Double Taxation on Income and on Capital. Under the Treaty, there is no withholding… – Continue reading

Base Erosion & Profit Shifting / Europe / Intellectual Property / Investments / OECD / Profit Shifting / Research and Development (R&D) / United Kingdom

___uk to modify patent box in line with oecd recommendations__

Posted On: December 14, 2015

Its approach includes a new “nexus principle”, as agreed by the multinational Organisation for Economic Cooperation and Development (OECD). This is designed to ensure that the benefits of the UK tax regime are only available where the research and development (R&D) expenditure required to develop that innovation also took place… – Continue reading

Advance Pricing Agreement / Dividends / Double Taxation / DTA / Intellectual Property / OECD / Offshore Investments / Profit Shifting / Tax Planning / Transfer pricing / Vietnam

An Overview of Transfer Pricing in Vietnam

Posted On: December 14, 2015

Transfer pricing is a tax planning method where related companies enter into transactions among each other to shift funds, and thereby profits. For instance, a parent company can extract funds from a subsidiary by having the issue a dividend, but the parent can also provide a service to subsidiary and… – Continue reading

Base Erosion & Profit Shifting / G20 / OECD / Permanent establishment / Transfer pricing

Tax Risk on Permanent Establishment: BEPS Action Plan 7

Posted On: December 13, 2015

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

Common Reporting Standard / EU / Isle of Man / OECD / Spain / Tax Information Exchange Agreements / United Kingdom

Isle of Man to be removed from Spain’s ‘tax haven blacklist’

Posted On: December 11, 2015

The Isle of Man has signed a tax information exchange agreement with Spain, reports the Isle of Man Today. It’s part of what the Manx government calls its ‘continuing commitment to meet international standards in tax co-operation and transparency’. The agreement was signed by Mr José Manuel Gutiérrez Delgado, Financial… – Continue reading

Base Erosion & Profit Shifting / Belgium / EU / Europe / Fiat / Legislation / Luxembourg / Netherlands / OECD / Starbucks / State Aid

TAXE: Have We Taken the Right Path To Ensure Fairer and More Efficient Taxation in the European Union?

Posted On: December 11, 2015

After the LuxLeaks affair in November 2014, the European Parliament established a special committee “on tax rulings and other measures similar in nature or effect” (TAXE) in February 2015. The committee’s report was adopted in a plenary session of the European Parliament on 25 November 2015. The Conference of Presidents… – Continue reading

Base Erosion & Profit Shifting / OECD / Transfer pricing

A new concept of intangible assets in the coming of BEPS?

Posted On: December 11, 2015

Under Action 8 of the BEPS project (Base Erosion and Profit Shifting) – Aligning Transfer Pricing Outcomes with Value Creation – work was carried out which resulted in certain changes to the OECD guidelines on transfer pricing (Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations), with special emphasis on… – Continue reading

Double Taxation / OECD / St. Kitts & Nevis / Tax Information Exchange Agreements

Exchange of Tax Information to Promote International Standards

Posted On: December 11, 2015

Basseterre, St. Kitts, December 11, 2015 (SKNIS): The proposed amendments to the Saint Christopher and Nevis Mutual Exchange of Information on Taxation Matters (Amendment) Bill, 2015 would greatly assist in minimizing the challenges that St. Kitts and Nevis faces when executing obligations under Agreements with treaty partners, said Prime Minister,… – Continue reading

Albania / Armenia / Automatic Exchange of Information / Azerbaijan / Botswana / Brunei / Burkina Faso / Cameroon / Common Reporting Standard / Costa Rica / Gabon / Ghana / Grenada / Guatemala / Kenya / Lesotho / Morocco / Niger / OECD / Pakistan / Panama / Papua New Guinea / Samoa / Senegal / Tanzania / Trinidad & Tobago / Uganda

Panama thumbs its nose at transparency – again

Posted On: December 10, 2015

We have on several occasions fingered Panama as a particularly recalcitrant secrecy jurisdiction: our recent Panama Narrative Report spills a fair number of beans in that respect. Its recalcitrance is perhaps hardly surprising, given the quantity of Colombian and Mexican drugs money believed to be sheltered there – to name… – Continue reading

Base Erosion & Profit Shifting / China / Glaxosmithkline / Investments / Ireland / Luxembourg / Netherlands / OECD / Research and Development (R&D) / Spain / Switzerland / United Kingdom / USA

The Changing Landscape for IP Regimes Around the World

Posted On: December 10, 2015

Patent Boxes, Innovation Boxes, Intangible Property Boxes, Knowledge Development Boxes (IP Regimes) – countries may use different names, but all of these regimes are designed to allow a preferential rate of tax to be applied to income generated from intangible property (IP). There are a number of these regimes in… – Continue reading

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