Category: OECD

CE + IT Multinationals Seek Talk With ATO As Avoidance Laws Near

CANBERRA – Several multinational companies have approached the Australian Taxation Office to negotiate before the Coalition Government’s tougher anti-avoidance laws take effect in January, tax commissioner Chris Jordan has said in opening remarks to the Senate inquiry into corporate tax avoidance. While not naming the companies, Jordan said he expects… – Continue reading

NIGERIA: IMPLICATIONS OF BEPS PROPOSALS

Nigeria’s tax authority—the Federal Inland Revenue Service—has incorporated into its tax audit procedures certain of the recommendations included in the OECD’s base erosion and profit shifting (BEPS) project. For instance, the tax authority is scrutinizing transactions between Nigerian subsidiaries and their foreign related parties, especially those related parties located in… – Continue reading

Tax functions need to fundamentally change the way they use and gather data

Employees in tax functions need to fundamentally change the way they use and gather data if they are to meet the growing demands on business of tax transparency, reform and technology enabled decision making. PwC’s latest research into the Tax function of the future – Unlocking the power of data… – Continue reading

Time for US to lead on international tax policy

In recent days, the new Speaker of the House Paul Ryan (R-Wis.) signaled a priority for international tax reform in 2016. And if the newest recommendations from the Organization of Economic Cooperation and Development (OECD) are any indication of what’s ahead on the global tax scene for American businesses, it… – Continue reading

Base erosion and profit shifting: limiting tax deductions for interest costs

Earlier this week the heads of state of the 20 largest global economies have agreed to adopt the 15 BEPS action points in their respective countries. Ample reason to take a closer look at the details and implications of one of the most far-reaching upcoming tax adjustments. Action 4 of… – Continue reading

United States: Tax Alert: G20 Leaders Approve OECD Proposals For Comprehensive Global Reform Of The International Tax System, Including Redefinition Of “Permanent Establishment”

Measures Will Impact Financial Services, Investment Fund, Aviation Leasing and Other Sectors G20 finance ministers last week finally approved the wide-ranging “BEPS” reforms to the international tax system. The measures include a proposed new OECD treaty definition of “Permanent Establishment” under which the mere negotiation of contracts could create a… – Continue reading

A Delicate Balance: Tax Competition Versus Cooperation

Tax administrators want to maximise the amount of revenue collected without stifling the county’s competitiveness as a business destination. How should ASEAN countries navigate changing international conditions to meet this goal? By Rebecca Tan – As Benjamin Franklin once famously said, “In this world, nothing can be said to be… – Continue reading

Crackdown on Caribbean tax havens a surprise boon for Hong Kong

Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading

KPMG leader visit highlights BEPS initiative

Latest developments under the Base Erosion and Profit Shifting (BEPS) initiative of the Organisation for Economic Co-operation and Development (OECD) was one of the key points of a recent four-day visit by KPMG’s global leader for Transfer Pricing Services Sean Foley to Vietnam. He shared the issue with Vietnam’s General… – Continue reading

Mutual Agreement Procedure (MAP) for navigating the tax tangle

If statistics are anything to go by, today India is the world’s fastest growing economy at 7.3% in 2015, outstripping the global average of 3.1%. With a new government in the centre, we do seem to be riding high on the growth trajectory. The Modi government has certainly done its… – Continue reading

Zuma, G20 back growth

18 November 2015 – The Group of 20 (G20) leaders have called for more collective action to achieve strong, sustainable and balanced growth that can be universally beneficial. In a communique issued at the end of the summit, the leaders agreed that not only do they have to do more… – Continue reading

AUSTRALIA: NEW TREATY WITH GERMANY REFLECTS BEPS RECOMMENDATIONS

The new tax treaty signed between Australia and Germany on 12 November 2015 is the first tax treaty Australia has signed that comprehensively incorporates the proposals in the OECD base erosion and profit shifting (BEPS) final recommendations. Some notable BEPS-related changes in the new Australia and Germany treaty include: The… – Continue reading

Corporate Coalition Pushes For US Patent Box

American Innovation Matters (AIM), a coalition of companies that includes Cisco, Boeing, Intel, Oracle and Facebook, has released a statement pushing for the introduction of a US patent box, or an “innovation box” as it is known in the United States. The statement looks at the endorsement on November 16… – Continue reading

South Korea Joins 94 Countries Enacting ‘Google Tax’

Google is said to have evaded paying an estimated $1.3 billion earned from selling apps in Korea based on the argument that their server is based in Ireland. The so called ‘Google Tax’, also known as the Base Erosion & Profit Shifting (BEPS) regulation, has been adopted this week by… – Continue reading

PwC calls for tweaks to S’pore tax system

Policies on perks, more bilateral pacts can help generate funds for growth: Accounting firm Singapore’s tax system can be improved to ensure the country can generate the funds needed for long-term growth and development, according to a white paper from accounting giant PwC yesterday. It called for policies that ensure… – Continue reading

Tax Commissioner Chris Jordan says tougher laws forcing multinationals to play ball

Tax Commissioner Chris Jordan says multinationals are already approaching the Australian Taxation Office to negotiate before the Turnbull government’s tougher anti-avoidance laws take effect in January, and he expects the office to reap $1.1 billion from them. We at the ATO acknowledge Australia needs investment by foreign companies in infrastructure… – Continue reading

Global Tax Network Will Impact Every Investor

Global tax is set to face the biggest shake up ever that will affect every saver and investor with accounts in any of the world’s major financial centres. Financial firms and governments are readying to start the Common Reporting Standard (CRS) from January 1, 2016. CRS is a souped up… – Continue reading

TaxTalk Today- 17th November 2015

PwC Australia Australian Taxation Office New or updated materials on ATO website, including: Decision impact statement on McGrouther & Anor v Commissioner of Taxation case concerning whether a taxpayer can waive or withdraw a notice given to the Commissioner under s14ZYA(2) of the Taxation Administration Act 1953 (requiring the Commissioner… – Continue reading

Widening the scope of Capital Gains Tax liability

One of the amendments proposed in the Taxation Laws Amendment Bill (TLAB), relates to the revision of the definition of “immovable property.” This definition is significant when considering the potential tax liability of non-resident persons, especially when it comes to capital gains tax (CGT). Paragraph 2 of the Eighth Schedule… – Continue reading

Tax Transparency – the Common Reporting Standard: Implications for South Africa

Globally, taxpayers are becoming more interdependent, and engage in cross-border financial activities with more regularity. With this, comes the need for enhanced co-operation and understanding across countries on issues such as tax administration and transparency, to curb tax evasion and ensure a fair allocation of taxes to tax jurisdictions. “The… – Continue reading

Tough debate with multinational companies on corporate tax practices

MEPs grilled eleven multinational companies on their corporate tax practices in a five-hour debate with the Special Committee on Tax Rulings on Monday. These companies had declined the committee’s first invitation to appear before it, but later changed their minds and accepted its last chance invitation. Of the 13 original… – Continue reading

EU Savings Directive repealed

On November 10th 2015, the European Council announced that the EU Savings Directive 2003/48/EC (EUSD) has been repealed in order to eliminate the overlap with other legislation developed in the aspect of preventing measures of tax evasion. Brief Background The 2003 EUSD, which originally came into effect on 1 July… – Continue reading

Tax transparency and reform leave nowhere to hide for tax functions of the future on data demands

The FINANCIAL — Employees in tax functions need to fundamentally change the way they use and gather data if they are to meet the growing demands on business of tax transparency, reform and technology enabled decision making. PwC’s latest research into the Tax function of the future – Unlocking the… – Continue reading

CATA Member Countries Serious In Tackling TP And BEPS Issues

MELAKA, Nov 17 (Bernama) — The Inland Revenue Board (IRB) has highlighted the transfer pricing (TP) and abuse of treaties in base erosion and profit shifting (BEPS) issues at the 36th Commonwealth Association of Tax Administrators Conference (CATA) here today. IRB, in a statement today, said CATA members were serious… – Continue reading

Retro tax still a concern for foreign investors: John Hobster

Foreign investors are still concerned about the retrospective taxation in India, but the concerns have alleviated a little due to assurances by the government, says John Hobster, global head (transfer pricing), EY. He tells Dilasha Seth that in terms of transfer pricing, things are changing in India not only at… – Continue reading

Luxembourg rated as “Largely Compliant” by the OECD Global Forum

On 30 October 2015, the Global Forum on Transparency and Exchange of Information for Tax Purposes published a supplementary peer review report for Luxembourg. Luxembourg, which was rated “Non-Compliant” in November 2013, has since implemented a number of recommendations made by the Global Forum, leading to an upgrade of its… – Continue reading

Transfer pricing: Shifting profits from hard-to-value intangibles

The need for robust, well-informed intangible asset valuations for the purpose of transfer pricing is becoming ever more invaluable for MNEs TRANSFER pricing has been the buzz-word of the moment with extensive media coverage in recent years of multinational enterprises (MNEs) repositioning profits to more favourable tax jurisdictions. This movement… – Continue reading

Developments in Transfer pricing and the impact of actions of OECD BEPS

2nd Symposium of CR for transfer pricing The 2nd Symposium Transfer Pricing organized by EY Greece, exactly one year after the successful organization of the 1st Symposium was intended as the developments in transfer pricing in Greece and international tax developments, focusing on the recently finalized OECD Actions tackling Erosion… – Continue reading

Canada: Navigating BEPS: What The Tax Function Of Today Needs To Know For Tomorrow

The Organisation for Economic Co-operation and Development (OECD) has described its newly unveiled Base Erosion and Profit Shifting (BEPS) Action Plan as a “change of paradigm.”1 A few very large global groups aside, a more apt description may be a minefield for the unwary. BEPS has received considerable air time… – Continue reading

BEPS – addressing the tax challenges of the Digital Economy and the “tax theory of everything”

When in 1915 Albert Einstein developed the general theory of relativity, providing a unified description of gravity, the impression was that said theory applies to big objects (like stars) as well as to small objects (subatomic particles). But during the following 15 years it was discovered that in the “small… – Continue reading

UK: Consultation Over Fixed Cap On UK Tax Deductibility Of Corporate Interest Expense: Plucking The Feather In The Cap?

The UK Government launched a consultation on 22 October 2015 regarding the UK corporate tax rules for interest deductibility. The consultation seeks views on the design of a general limitation for UK corporation tax deductions for interest and similar finance costs, imposing a capcalculated by reference to a fixed percentage… – Continue reading

Switzerland & Luxembourg among DTA approvals sent for US Senate vote

Eight tax treaties and protocols were passed forward for a ratification vote by the full US Senate at a business hearing of the Committee on Foreign Relations on November 10, reports Tax News. The Committee approved the new US double taxation agreements (DTAs) with Chile and Hungary, and protocols to… – Continue reading

BEPS AND QATAR OUTBOUND INVESTORS – MANAGING REPUTATIONAL RISK AND PREPARING FOR CHANGE

Across the globe, base erosion and profit shifting (BEPS) is making headlines and drawing the attention of not only governments and tax authorities but also non-government organizations, activists, lobbyists and the general public. As the public debate has spread to the Gulf Cooperation Council (GCC) countries, the focus now centers… – Continue reading

Common Reporting Standard (CRS) effective 1 January 2016; self-certification forms/ documentation update (13 November 2015)

The Common Reporting Standard (CRS) impacts Irish funds from 1 January 2016. The CRS framework represents a globally coordinated approach to the disclosure of income earned by individuals and organisations in order to combat tax evasion. It emerged from the Organisation for Economic Co-operation and Development (OECD) in February 2014… – Continue reading

Uber, Airbnb to be hauled before Senate inquiry into corporate tax avoidance

What does Uber mean for Canberra? Journalist Henry Belot explains how Uber will work in the ACT and what it means for passengers and drivers. Uber and Airbnb will be dragged before the Senate inquiry into corporate tax avoidance this week to face questions about tax structures that allow them… – Continue reading

Belgian fight against tax evasion

As a reminder, the international automatic exchange of financial account information is considered by most countries as particularly efficient in the fight against tax evasion and international tax fraud and is becoming the new global standard (considering the US FATCA legislation, the OECD Common Reporting Standard). The Belgian Council of… – Continue reading

Anatomy of transfer pricing

Currently 15,980 foreign companies are operating in Korea. While hiring workers and producing goods and services, foreign investors encounter numerous difficulties and experience a variety of grievances. One particular grievance brought to our attention is that they suffer from a discrepancy between the value of imported goods assessed by the… – Continue reading

G20 vows balanced growth – Capital flow a concern

Antalya, Nov. 16: The Group of 20 nations today pledged to adopt sound macroeconomic policies to achieve strong, sustainable balanced growth. The near-term objective would be to support growth, create jobs and put debt as a share of gross domestic product (GDP) on a sustainable path. Data show that several… – Continue reading

BEPS tax reforms ‘cannot be the endpoint’, G20 told

The OECD’s base erosion and profit shifting (BEPS) reforms do not go far enough in changing the international corporate tax system, G20 leaders have been told. In a letter to leaders at the G20 summit in Antayla, Turkey, Nobel Prize-winning economist Joseph Stiglitz and others from the Independent Commission for… – Continue reading

MEPs accuse US multinationals of diverting profits to low tax havens

Amazon, Facebook and Google in line of fire after committee backs proposals to force multinational corporations to pay tax where they make their sales MEPs have launched a scathing attack on Facebook, Google and Amazon in the European parliament, accusing them of diverting profits worth billions of pounds to low… – Continue reading

After Outcry, Ireland Adjusts Its Corporate Tax Draw

CORK, Ireland — As lord mayor of this quiet seaside city in southern Ireland, Chris O’Leary seems to have a situation most other local politicians can only dream about. Blue-chip international companies like Apple, Dell and IBM have all set up shop in and around this city, filling newly built… – Continue reading

Cantillon: no escape from tax talk at G20 summit

Leaders of world’s major economies gather in Turkish city of Antalya Leaders of the world’s major economies gather in the Turkish city of Antalya this weekend for the tenth annual G20 summit. The summit takes place at a sensitive moment in international affairs. The war in Syria and the resulting… – Continue reading

OECD holds first Asia-Pacific Technical Meeting on BEPS in Indonesia

3/11/2015 – On 11-12 November 2015, the first Asia-Pacific Technical Meeting on BEPS discussed the outcomes of the BEPS Project, and the challenges countries face in the region in implementing BEPS, and explored how countries in the region can engage in the implementation, on-going development and monitoring of the measures… – Continue reading

Contractors urged to get international tax affairs in order

Contractors working abroad have been urged to get their international tax affairs in order following the introduction of new legislation. The Organisation for Economic Co-Operation and Development (OECD) has put in place a new automatic exchange of tax information, which means countries across the globe will able to access much… – Continue reading

France backs country-by-country corporate tax reporting from 2016

French lawmakers sought to tackle corporate tax avoidance on Thursday, voting to require big French companies to report tax information on their foreign activities on a country-by-country basis from 2016. The French government wants to get an early start on implementing an OECD recommendation for country-by-country reporting that aims to… – Continue reading

Australia-Germany Sign Tax Treaty; Michael Turnbull Visits for Submarine Bid

In the first step towards boosting trade and investment between the two nations, Australia and Germany have signed a new tax treaty in Berlin. It also marks an attempt to improve the integrity of the tax system by pinning down on multinational tax evasion. The deal, which preceded the arrival… – Continue reading

Commentary: Tax havens: The need for action – Part 2

By the very criteria set in the United States by the Multistate Tax Commission (MTC), several states in the US are “tax havens”. But, they have not been named in the legislation passed by the legislatures of Oregon, Montana and others. Among the MTC criteria for determining a tax haven… – Continue reading

Oxfam urges G20 leaders to take action on climate change, refugees and tax reform

G20 countries spend over 15 times subsidizing the coal and oil industry than developed countries provide in adaptation finance to poor and vulnerable countries, said Oxfam today, ahead of the G20 Summit in Antalya, Turkey. Oxfam also urged the G20 leaders to tackle fundamental reforms to ensure the benefits of… – Continue reading