Category: OECD

El Salvador signs multilateral convention to fight tax evasion

El Salvador has become the latest country joining international efforts to fight offshore tax evasion. The Central American nation yesterday signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. In doing so, El Salvador has become the 86th member worldwide, the eighth Latin American country and the third… – Continue reading

United States: U.S. Treasury Department Releases Proposed Model Treaty Provisions

On May 20, 2015, the U.S. Treasury Department released for public comment draft updates to the U.S. model income tax convention and its accompanying Technical Explanation (collectively, the “Model Treaty”), which was last updated in 2006. The Model Treaty is the template that Treasury uses as its starting point in… – Continue reading

The Bahamas Chooses the Path of Innovation, Compliance

The past decade or more has not been an easy road to manoeuvre for IFCs. The Bahamas like other IFCs has faced the combined challenges of international initiatives, increased competition, industry consolidation, changing client demographics, emerging market requirements; legacy market stagnation and of course the financial crisis just a few… – Continue reading

Hong Kong: Will The Very Efforts Designed To End The Offshore Industry Finally Legitimise It?

Since the beginning of the global financial crisis, politicians, the media and people on the street have engaged in a series of “blame games” to point fingers and punish those responsible for their own economic ills. For the past few years, one “culprit” has been firmly in the spotlight –… – Continue reading

Island’s links with the Northern powerhouse worth promoting

A full and fascinating roundtable discussion based around the island’s place as an international finance centre was held at KPMG’s headquarters in Athol Street, Douglas. Around the table were David Karran, managing director, IQE, Simon Scott, managing director, Barclays Isle of Man, Andrew Thomas, chief executive, Isle of Man Enterprises… – Continue reading

Australia signing up to global tax effort

AUSTRALIA is onboard for the international effort to upgrade a creaking 100-year-old global tax system. AUSTRALIAN Tax Commissioner Chris Jordan told a Senate committee on Tuesday the present tax architecture was developed in the early 1920s for the now defunct League of Nations. It also depended on the physical presence… – Continue reading

Africa: A Journey Toward an African Taxation Renaissance

Africa is known as the ‘paradox of plenty’. How can a continent so rich in natural resources be so poor? Economic growth is predicted to increase by 4.5% across the continent this year, despite falling oil prices and the Ebola crisis. South Africa’s economy, the second biggest in Africa is… – Continue reading

Switzerland and EU sign historic agreement on financial information exchange

The European Union and Switzerland signed a bilateral agreement on the automatic exchange of financial information on Wednesday morning, reports Ahram Online. According to the Neue Zürcher Zeitung (NZZ), a major Swiss newspaper, the agreement commits both parties to collect information on banking accounts starting in 2017 and exchanging this… – Continue reading

FIFA-Gate: Costa Rica football federation says US ‘mistaken’ in Eduardo Li wire fraud allegation

The leadership of Costa Rican football has circled the wagons around their embattled president, Eduardo Li, after Li was arrested in Zurich, Switzerland, Wednesday on charges of racketeering, wire fraud and money laundering. Jorge Hidalgo, acting president of the Costa Rican Football Federation, FEDEFÚTBOL, told the website Amelia Rueda that… – Continue reading

Guernsey: Guernsey Issues Amended Legislation And Updated Draft Guidance Notes On FATCA-Based Reporting

On 31 March 2015 amendments were made to the Income Tax (Approved International Agreements) (Implementation) (United Kingdom and United States of America) Regulations, 2014 (the “2014 Regulations”) which brought FATCA-based reporting into force under Guernsey law. FATCA-based reporting is implemented in Guernsey pursuant to the UK-Guernsey IGA, signed on 22… – Continue reading

Switzerland, Italy Talk Tax Cooperation

Swiss and Italian foreign ministers recently met to discuss taxation, finance, transport, and other cross-border issues. Didier Burkhalter, head of Switzerland’s Federal Department of Foreign Affairs, received Italian Foreign Minister Paolo Gentiloni for official talks in Bern on May 28. The ministers welcomed the bilateral agreement on finance and taxation… – Continue reading

Tax Planning And Portugal’s Non Habitual Residence Scheme

Portugal can be a very attractive country to live in from a tax point of view. The inheritance tax regime is very benign here, and there is no wealth tax. Tax efficient arrangements can lower tax liabilities on your investment and pension income. And if you are a new resident,… – Continue reading

UK: Patent Box – More Detail On The New Regime

Following our article at the end of last year on the potential changes to the UK patent box regime further details have been released on the new regime, timings and additional work to be done. On 6 February 2015, the Organisation for Economic Co-operation and Development (OECD) published a paper… – Continue reading

Raising your next fund: the rising tide of global regulatory change

There has recently been a wave of global regulatory reforms which affect fundraising. These changes are far-reaching and can impact how fund managers structure funds, their proposed investor base, how and where funds are marketed, the remuneration that may be received, registrations that may be required and dealings with investors…. – Continue reading

Oman: Taxpayers set to face more scrutiny

Muscat: Taxpayers across the globe, including Oman, are facing increased scrutiny of their tax returns and positions taken as the pressure on governments increases to raise revenues from taxes, says an expert at KPMG. Ashok Hariharan, partner and head of tax for KPMG in the Middle East and South Asia… – Continue reading

OECD BEPS will have big impact on taxes for multinational (re)insurers

The Organization for Economic Co-operation and Development (OECD) published its Base Erosion Profit Sharing (BEPS) action plan in July 2013 to address perceived flaws in international tax rules. The Plan was endorsed by G20 with implementation to be completed by the end of 2015. spoke with John O’Leary, a… – Continue reading

Mexico: Risks And Opportunities From A Mexican Tax Perspective

Investments Derived From Structural Reforms The approved structural Reforms are an unprecedented opportunity for a transformational economic growth in Mexico, being the most relevant from an investment point of view the reforms related to Energy, Telecommunications and Antitrust, which have put Mexico in the radar of Multinational companies seeking to… – Continue reading

Transfer prices: international environment and its impact on national legislation and regional operations

The countries of the Central American region have incorporated and reformed their legislations to the international regulations of Transfer prices and practically all the applicable legal provisions to related parties have already been expanded in the region, which implies, that the companies with regional presence must visualize, review and engage… – Continue reading

Caribbean IFCs: Looking Beyond the International Initiatives

Caribbean IFCs continue to face the growing challenges as global standards struggle to manage certain risks across borders. Some of these challenges (such as cross border tax information sharing) have maintained their original format but intensified and we have seen several new initiatives (for example a push for beneficial ownership… – Continue reading

Amazon begins to book revenues in separate countries in what expert says is response to regulatory pressure

E-commerce giant Amazon has begun booking revenue in individual European companies, a move that tax expert Heather Self of Pinsent Masons, the law firm behind, said is probably influenced by upcoming regulatory changes.26 May 2015 “As of 1 May, Amazon EU Sarl is recording retail sales made to customers… – Continue reading

EU Tax Committee Hears From Switzerland

A delegation from the European Parliament’s Special Tax Rulings Committee visited Switzerland on May 22. The delegation was received by Switzerland’s State Secretary for International Financial Matters, Jacques de Watteville. According to the Swiss Federal Council, talks focused on international corporate tax reform efforts and Switzerland’s work in this area…. – Continue reading

Transfer pricing presents risks and opportunities

Businesses that operate globally continue to face complex tax issues, and transfer pricing – the practice of establishing arm’s-length prices for related-party cross-border transactions – has become more important than ever. When it comes to transfer pricing, I consider the Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational… – Continue reading

Transfer pricing law new weapon

Thailand’s capacity for tracking how multinational companies shift income across borders within the same group to understate tax payments will increase after a transfer pricing law comes into force. The transfer pricing law, which is being deliberated by the Council of State, will authorise Revenue Department officials to ask parent… – Continue reading

To have and have not

Argentine political analysis is increasingly introspective but sometimes it is worth looking at developments in the wider world in order to place things in perspective. The substantial rise in the tax burden over the past decade has led to plenty of local moaning and groaning at both national and provincial… – Continue reading

Belgium and Russia sign new tax treaty

Belgium and the Russian Federation announced in March 2007 that they would negotiate a new double tax treaty (the “Treaty”). Nearly seven years after discussions began on 20 November 2008, the Treaty was finally signed on 19 May 2015 in Brussels. This newsflash is based on an unofficial version of… – Continue reading

Diverted Profits Tax: counterbalancing the UK’s “open for business” agenda?

The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of April 1, the DPT seemed intended to appease public anger at multinationals failing to pay their ”fair… – Continue reading

Gibraltar: Gibraltar Financial Services Commission

FSC restructuring plans for 2015 he Gibraltar Financial Services Commission (FSC) has recently announced restructuring plans for 2015. The restructure will take effect on 1 January 2015, focussing on supporting efficient and effective delivery of the FSC’s regulatory objectives and with a particular focus on strengthening existing sector-specific expertise. This… – Continue reading

Georgia seeks broader economic ties with Poland

Georgia and Poland held negotiations in Warsaw this week over an agreement on avoiding double taxation on income and capital. At the bilateral meeting the sides initialed the renewal agreement, which is based on the OECD Model Convention 2014 and envisages the introduction of new standards of cooperation in taxation… – Continue reading

Valeant Pharmaceuticals, Concordia Healthcare zoom ahead of U.S. peers

Canada’s health-care stocks are sizzling, as Concordia Healthcare Corp. and Valeant Pharmaceuticals International Inc.’s buy-and-streamline strategy has pushed the industry’s earnings and margins ahead of U.S. peers. The drugmakers are the two top-performing stocks in the Canadian equity benchmark this year, boosting total returns for the members of the Standard… – Continue reading

Global attempt on to ensure MNCs cough up proper taxes

OECD, G20 team up to plug loopholes that allow companies evade taxes in jurisdictions they operate to prevent tax base erosion There is now a serious global attempt to ensure that multinationals pay taxes in the jurisdiction in which they carry out their business. The attempt is being made keeping… – Continue reading

Jersey: Jersey Described As ‘One Of The First And Best’ In Shaping Transparency Landscape At London Conference

Jersey’s positive role in helping to drive forward and shape the international transparency landscape has been praised by a senior OECD tax expert at this year’s Jersey Finance Annual London Private Client Conference. Addressing an audience of more than 400 senior private client tax, trust and wealth management professionals at… – Continue reading

Jersey: Jersey Described As ‘One Of The First And Best’ In Shaping Transparency Landscape At London Conference

Jersey’s positive role in helping to drive forward and shape the international transparency landscape has been praised by a senior OECD tax expert at this year’s Jersey Finance Annual London Private Client Conference. Addressing an audience of more than 400 senior private client tax, trust and wealth management professionals at… – Continue reading

Resolving cross border tax disputes through Australia’s investment treaties

1. Global focus on transfer pricing There has been a recent surge in regulatory attention around the world towards pricing arrangements within multinational corporate groups. Regulators are concerned that these pricing arrangements may be used as a means of profit shifting and therefore tax avoidance. The price at which an… – Continue reading

OECD strengthens recommendations on transfer pricing documentation

In 2014, the Organization for Economic Co-operation and Development (“OECD”) began making recommendations to Member States for the implementation of certain actions aimed at limiting base erosion and profit shifting, known as “BEPS”. The project includes 15 actions, representing 15 areas of regulation that allow states to monitor data which… – Continue reading

New rules soon to tackle offshore tax deferral

The finance ministry will in the near future add Controlled Foreign Corporation (CFC) rules to the Income Tax Act in order to prevent the tax deferral that many Indian multinational companies resort to by not repatriating the profits of their foreign subsidiaries for long periods. The proposed rules will come… – Continue reading

Tax planning, tax avoidance and the OECD

Introduction Tax avoidance, however legitimate its mechanism, has become the new focus for public opprobrium in parts of the world. High-profile cases and media attention examining the tax strategies of major global companies operating primarily in the digital economy have all contributed to this shift of focus. How are the… – Continue reading

Switzerland: Landmark Judgments Regarding The Refund Of Swiss Withholding Tax

INTRODUCTION On May 5, 2015 the Swiss Federal Supreme Court held a public hearing about two cases relating to the reclaim of Swiss withholding tax (WHT) in connection with arbitrage cases and issued its long awaited decisions. Two Danish banks issued the question on treaty entitlement for the refund of… – Continue reading

How McDonald’s dodged half a billion dollars in Australian tax

International fast-food giant McDonald’s avoided paying half a billion dollars of tax in Australia over a five-year period by shifting profits through the low-tax nation of Singapore, a new report by a global coalition of trade unions says. The report, which has been funded and commissioned by a coalition of… – Continue reading

Black money trail: India in talks with 28 nations for info

NEW DELHI, MAY 19: In its ongoing quest to draw information on illegal incomes stashed abroad, the Indian revenue authorities are in negotiations with as many as 28 different countries/jurisdictions for tax information exchange agreement (TIEA). This agreement will enable Indian tax authorities to receive banking related information even from… – Continue reading