Category: OECD

Define a tax haven, business lobbies tell government

Before going after multinationals that channel profits through tax havens and low-tax nations, you must define what one is, business lobbies have told the Abbott government. Treasurer Joe Hockey announced in the May budget that the government would be strengthening anti-avoidance laws to go after 30 companies with over $1… – Continue reading

Poland removes Bermuda from ‘blacklist’

A controversial Euro list of dodgy tax jurisdictions that included Bermuda has been dealt a blow after Poland said the Island should not have been included on its submission. The move came after the European Commission unveiled the 30-jurisdiction ‘blacklist’ of non-cooperative tax jurisdictions singled out by member states. Poland… – Continue reading

C’tee recommends tax breaks on IP brought to Israel

Companies registering their intellectual property in Israel will be charged only 5% tax on dividends. The committee considering changes in the Law for the Encouragement of Capital Investments, headed by former Ministry of Finance director general Yael Andorn, is recommending extension of the tax break granted under the law to… – Continue reading

U.S. Treasury attempts to influence OECD’s BEPS initiative via proposed changes to U.S. model treaty

The United States has been criticized on more than one occasion for failing to be a meaningful participant in the OECD’s multi-pronged initiative to address base erosion and profit shifting (BEPS). Some commentators have even gone so far as to accuse the United States of actively working against the BEPS… – Continue reading

Crackdown on multinational tax avoidance likely to be thwarted, says expert

The G20’s efforts to crack down on multinational tax avoidance are likely to be defeated by national self-interest, particularly from the United States, one of Australasia’s top tax advisers says, reports the Sydney Morning Herald. Rod Houng-Lee, formerly Asia Pacific Tax Leader head of tax in Asia Pacific for big-four… – Continue reading

Bahamas ‘unfairly dumped on’ with EU blacklisting

The Bahamas was yesterday “dumped on” through its inclusion on another so-called financial services ‘blacklist’, although an ex-Attorney General and others suggested the development should be taken “with a big grain of salt”, reports the Bahamas Tribune. John Delaney told Tribune Business that the European Union’s (EU) decision to ‘blacklist’… – Continue reading

Professions resist key components of OECD tax plan

Accounting and legal professions in Ireland oppose major strands of business tax plan Key strands of the Organisation for Economic Co-operation and Development plan (OECD) to overhaul global business tax rules have run into resistance within the accounting and legal professions in Ireland. A submission this week to the Paris-based… – Continue reading

UK trips up EU plan to ham string industrial-scale corporate tax avoidance

Britain will not adopt new EU measures to tackle large-scale tax avoidance by multinational companies, the financial secretary to the Treasury has said. Brussels hopes to implement a longstanding tax harmonization plan to set common rules across member states, thereby closing legal loopholes multinationals currently exploit. A German member of… – Continue reading

South Africa: Country-Mauritius Tax Treaty Comes Into Force

Pretoria — Government has gazetted the South Africa-Mauritius tax treaty which came into force at the end of May, said National Treasury. “This new treaty reflects changes in the tax policies of the two countries and is in line with international best practices to deal with tax abuse as outlined… – Continue reading

Cyprus: The New Cyprus-Iceland Double Taxation Agreement

With less than seven weeks between signature on 13 November 2014 and entry into force on 22 December, the new DTA between Cyprus and Iceland set a new standard for timeliness. Like most of Cyprus’s recent double taxation agreements, the DTA closely follows the form of the 2010 OECD Model… – Continue reading

Caribbean states urged to object to EU tax-haven blacklisting

Critics of an EU tax-haven blacklist say the organisation is playing dice with small states’ reputations, while ignoring European tax avoidance hubs BRIDGETOWN, Barbados, June 19, 2015 (AMG) — Doubts have been cast over the methodology and motives behind the naming of fourteen Caribbean countries among a list of thirty… – Continue reading

Global net closes on tax dodgers

International tax rules will soon change, but companies’ behaviour may change sooner. There will soon be fewer places for multinational companies and ultra-rich individuals to squirrel away money. In November leaders of the G20 are expected to adopt a full range of measures to curb the practices of base erosion… – Continue reading

Tax transparency – the road ahead

In the last few years, particularly following the credit crunch, there has been a tangible focus on tax avoidance and clamping down on tax planning. Overnight, the rules of the game were changed and what was previously considered to be legitimate tax planning was condemned as being aggressive and morally… – Continue reading

‘Surprise’ at Guernsey inclusion on EU ‘non-cooperative’ blacklist

Guernsey’s Chief Minister and Commerce and Employment Minister have expressed their astonishment that Guernsey has been included on a list of 30 so-called ‘non-cooperative’ non-EU jurisdictions, which was published today, reports Guernsey Finance. The list consolidates national tax ‘blacklists’ as they stood six months ago, and includes any jurisdiction on… – Continue reading

Cayman Islands: CRS Update And Impending FATCA Return Deadline

Following the expiration of the 29 May 2015 notification deadline with the Cayman Islands Tax Information Authority (the “TIA”), the next step for all Cayman Islands Reporting Financial Institutions (each an “RFI”) is to submit a return (the “FATCA Return”) setting out certain details of any US Reportable Accounts that… – Continue reading

Allegation of Hong Kong as non-cooperative tax jurisdiction totally unfounded

Hong Kong (HKSAR) – The Hong Kong Special Administrative Region Government today (June 18) expressed regret over the inclusion of Hong Kong in the list of non-cooperative tax jurisdictions published by the European Commission. “Hong Kong has all along been supportive of international efforts to enhance tax transparency and combat… – Continue reading

Proposed U.S. Model Treaty Provisions May Dramatically Alter International Tax Landscape

The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners should be aware of the potential impact those changes can have on their existing inbound U.S. structures…. – Continue reading

Bahamas: Financial Industry fears FATCA start with no legislation

The Bahamian financial industry is concerned it will have to start reporting information for the US Foreign Account Tax Compliance Act (FATCA) without the necessary legislation being in place, Tribune Business can reveal, reports the Bahamas Tribune. Lawrence Lewis, a Deloitte & Touche (Bahamas) partner and accountant, confirmed to Tribune… – Continue reading

Wal-Mart Has $76 Billion in Overseas Tax Havens, Report Says

Wal-Mart Stores Inc. owns more than $76 billion of assets through a web of units in offshore tax havens around the world, though you wouldn’t know it from reading the giant retailer’s annual report. A new study has found Wal-Mart has at least 78 offshore subsidiaries and branches, more than… – Continue reading

Can The United States Kill BEPS?

The United States is through trying to needle the OECD’s base erosion and profit-shifting project with pinpricks. Last week, Robert Stack, U.S. Treasury deputy assistant secretary (international tax affairs), abandoned the subtle digs Treasury had been using to attack BEPS and flat-out said the United States is extremely disappointed in… – Continue reading

Financial Industry Fears Fatca Start With No Legislation

The Bahamian financial industry is concerned it will have to start reporting information for the US Foreign Account Tax Compliance Act (FATCA) without the necessary legislation being in place, Tribune Business can reveal. Lawrence Lewis, a Deloitte & Touche (Bahamas) partner and accountant, confirmed to Tribune Business that there was… – Continue reading

Airbnb, Amazon Land on French Senators’ Tax Radar as Sales Soar

France is trying to squeeze more out of web businesses like EBay Inc., Amazon.com Inc. and Airbnb Inc. Soaring online sales and the use of the Internet giants by smaller businessses as a marketplace for goods and services is prompting the French Senate to look for ways to collect more… – Continue reading

Birth of a New Era in Private Wealth

As the financial world continues its march towards a more transparent and open environment, regulations governing private wealth are under scrutiny. The traditional is changing for good while new players emerge. Once was a time, not too long ago, the words “Swiss bank” conjured up evocative imagery: secret deals; bank… – Continue reading

TAXE – a fundamental shift in ruling practice?

The LuxLeaks financial scandal, which entailed disclosure by the International Consortium of Investigative Journalists of tax rulings, galvanized public opinion and gave rise to the creation of TAXE, the European Parliament’s special committee on tax rulings. This article explains why TAXE was created and shares with you highlights from the… – Continue reading

Divisions in US over OECD corporate tax proposals

Senior Republicans voice concerns over Obama administration’s response to plan Political divisions are opening up in Washington over the US response to the overhaul of international tax rules by the global powers, an initiative with big implications for Ireland’s corporate tax regime. The Republican leaders of the two tax-writing committees… – Continue reading

Nigeria Sends Clear Signal of Getting Serious on Tax Evasion, Avoidance

With revenue from petroleum taxes at its lowest point in fifteen years, Nigeria is under even more pressure to tackle tax evasion and pursue other revenue enhancing initiatives. Indeed, experts have found that tax evasion plays a significant part in the over $50 billion that the continent loses every year… – Continue reading

Financial institutions must prepare for ‘FATCA on steroids’

Financial institutions around the world must ‘get their act together’ for the introduction of the OECD’s Common Reporting Standard (CRS) in seven months, Linedata has warned. Justin Hayes, product manager at the international software provider, dubbed the automatic exchange agreement between an initial 58 countries “FATCA on steroids’ and an… – Continue reading

FactCheck: Christie’s tax dodge

He has distorted the facts about the nation’s current tax system. Chris Christie repeatedly has said that U.S. corporations are taxed twice on income earned abroad, claiming in one speech that IRS officials “don’t recognize the tax you paid to a foreign country.” That’s false. It’s true that the U.S…. – Continue reading

APAs key to resolve transfer pricing disputes

Transfer pricing has emerged as a key focus area both globally and locally. From an international scene, the OECD/G20 venture — a club of advanced countries in Europe and North America, has been working on action plans to help tax administrations deal with Base Erosion and Profit Shifting (BEPS) project…. – Continue reading

Swiss federal council adopts AEOI dispatch

The Swiss Federal Council has submitted to Parliament dispatches on the implementation of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters and the Multilateral Competent Authority Agreement on the Automatic Exchange of Financial Account Information (MCAA), reports Tax News. Developed by the Organisation for Economic Cooperation and Development… – Continue reading

Bermuda: Minister Richards examines global tax threats

Speaking at the Insurance Day 2015 Summit on 10 June 2015, Minister of Finance Bob Richards told attendees that “the more we drive home that the insurance sector in Bermuda is not a stereotypical tax haven gimmick to key onshore decision makers the less the threat from IRS and other… – Continue reading

Canada: The Estate Planner: The Effective Use Of Trusts In Connection With Income Splitting – Part IV Of IV

Part I of this series of articles reviewed some of the basic tax requirements for using trusts to split income, Part II discussed a number of tax planning opportunities that can be accessible through the use of trusts, and Part III reviewed traditional testamentary trust income splitting planning and the… – Continue reading

G7 to Clamp Down on Tax Avoidance Via Transfer Pricing

Multinational firms said to be ‘cheating’ African countries out of billions of dollars that could be used for health care and education. G7 leaders Monday pledged to reform the international tax system by minimizing transfer pricing, according to Public Finance International. Transfer pricing involves internal transactions between a large company’s… – Continue reading

G7 fails to stop the dirty money trail, tax evasion

Dirty money resulting from crime, corruption and tax evasion is estimated to cost over one trillion dollars every year. It exacerbates poverty and inequality, and should be regarded as one of the most pressing issues globally. An Oxfam report found that G7-based companies and investors cheat Africa out of tens… – Continue reading

Australia plans new law on tax avoidance

Sydney, 10 June (Argus) — The Australian government has released legislation to tighten rules governing corporate taxation such as the use of offshore tax havens. The bill is not aimed at any particular sector of the economy, but several resource and commodity companies have come under scrutiny following a Senate… – Continue reading

Bahamas: Financial services keeping up with international best practices claims Strachan

Minister of Financial Services the Hon. Hope Strachan said international best practices are evolving at a rapid pace, particularly as it relates to automatic tax exchange initiatives, tax transparency, anti-money laundering and financial crime, and e-commerce, reports the Bahamas Weekly. Making her contribution to the 2015 Budget Debate in the… – Continue reading

G7 leaders move toward automatic exchange of tax information

Heads of state meeting at the G7 Summit in Bavaria, Germany committed to promoting automatic exchange of tax information and tax rulings to discourage multinational companies from shifting profits from country to country to avoid taxes, reports Accounting Today. In a joint declaration, the G7 leaders reaffirmed their commitment to… – Continue reading

Hong Kong needs to catch up with latest global tax standards

Hong Kong, as a world financial centre, will undertake legislative changes to implement automatic exchange of information of account holders Exchange of information is a recognised tool to enhance tax transparency and combat cross-border tax evasion. As a major financial centre, Hong Kong is committed to following global standards. While… – Continue reading

Argentine Supreme Court rule on transfer pricing of commodity exporters

The Argentine Supreme Court ruling on Toepfer International, a commodity exporting firm, has finally been published, tw o months after the decision, providing lessons for BEPS action 10 (cross border commodity transactions). This case, AFIP v Alfred C Toepfer Internacional, belongs to the first group of three controversies, related to… – Continue reading

Recent Tax Treaty Developments In Cyprus

Proposed Amendments To Cyprus’s Assessment And Collection Of Taxes Law The Cyprus Government has published a draft law amending the Assessment and Collection of Taxes Law (Law 4 of 1978) in order to facilitate implementation of agreements for automatic exchange of information with other countries. When it is enacted, the… – Continue reading

OECD releases Implementation Package for BEPS country-by-country reporting

08/06/2015 – Pushing forward efforts to boost transparency in international tax matters, the OECD today released a package of measures for the implementation of a new Country-by-Country Reporting plan developed under the OECD/G20 BEPS Project. The Country-by-Country Reporting Implementation Package will facilitate a consistent and swift implementation of new transfer… – Continue reading

BEPS: The impact of the interest limitation rule on investment

OVERSEAS investment by Thai companies has been surging in recent years and this trend is almost certain to continue. One of the questions frequently asked by Thai investors when seeking to acquire foreign operating companies or establish overseas subsidiaries is what type of funding structure would be the most tax… – Continue reading

Tax proposals for multinationals will have ‘massive impact’

OECD propose country-by-country reports on their financial affairs Proposed new obligations on multinationals to produce country-by-country reports on their financial affairs will have a “massive impact” on them, a leading member of the Organisation for Economic Development and Cooperation has said. Pascal Saint-Amans , director of the Center for Tax… – Continue reading

Switzerland plans stringent norms to fight black money menace

BERNE: Amid a global black money crackdown including by India, Switzerland has announced a stringent due diligence regime for its banks to ‘reject’ accepting illicit funds from both existing and new customers. Swiss banks, known for their strict secrecy practices, would also terminate relationships with existing clients who are found… – Continue reading

Transfer pricing is a tricky game

The resurgent interest in transfer pricing abuse by multinationals might be missing the first “link in the chain” – the shifting of profits inside South Africa to the detriment of empowerment partners, workers, communities and the economy. This is the emerging line from a prominent think-tank, the SA Mining Development… – Continue reading