On July 8, 2015, the International Tax Reform Working Group, which is co-chaired by Senators Rob Portman (R-OH) and Chuck Schumer (D-NY), released its long-awaited report that Senate Finance Committee Chairman Orrin Hatch (R-UT) has said is the precursor to comprehensive tax reform in the United States. What does the… – Continue reading
On 4 June, the Organisation for Economic Co-operation and Development (“OECD”) published a discussion draft on “hard-to-value-intangibles” in terms of which the OECD proposes revising its Transfer Pricing Guidelines. In particular, it is proposed that tax authorities will be allowed to use ex post “evidence”, (i.e. hindsight), to assess the… – Continue reading
The Executive Board of the International Monetary Fund (IMF), on July 6, 2015, discussed the IMF’s role in supporting the post-2015 development agenda, ahead of the upcoming third United Nations (UN) Conference on Financing for Development (FfD) to be held in Addis Ababa from July 13–16, 2015. Having adopted a… – Continue reading
The ministry of financial services has announced that Cayman will implement the OECD common reporting standard later this year. The CRS standardizes the global automatic exchange of information for tax purposes. Automatic exchange of information will ultimately lead to the transmission of large amounts of data, such as the investment… – Continue reading
Japan’s Ministry of Finance said international policy veteran Masatsugu Asakawa will become the country’s top financial diplomat, whose tasks include co-ordinating with other nations and the IMF as well as arranging currency interventions. Asakawa’s broad network with policymakers both inside and outside Japan puts him in an ideal position to… – Continue reading
Step aside, Doctors Without Borders. A new class of professionals is ignoring national frontiers to come to the aid of economically struggling nations. A team called Tax Inspectors Without Borders will begin helping developing countries deal with the flood of income to low-tax jurisdictions once it’s established next week by… – Continue reading
Barbados and other Caribbean leaders who held a recent summit in Bridgetown want the European Union to lift the blacklisting of Caribbean offshore jurisdictions immediately, reports the Barbados Advocate. The demand is contained in the Heads of Government Communique which was issued following the July 2-4 summit at the Hilton…. – Continue reading
Agreement with Mauritius to be renegotiated. National Treasury says the abuse of double tax agreements by multinational companies is the main reason why the agreement with Mauritius has been renegotiated. National Treasury head of tax and financial sector policy Ismail Momoniat says companies have often used dual tax residence structures… – Continue reading
The FINANCIAL — Tax is firmly under the spotlight and in the global insurance industry, the ramifications for finance and tax teams will be felt in both a new set of business demands and an overhaul of how these functions interact and operate. However, a new report from PwC says… – Continue reading
NEW YORK – When it comes to funding development, taxes are perhaps the most critical piece of the puzzle. But the system of taxing global profits is broken – and it is exacerbating inequality both within and across countries. If the world is to make progress toward its goals of… – Continue reading
The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) – the leading international standards-setter for tax transparency and cooperation – has underlined Guernsey’s reputation as a cooperative jurisdiction, reports Guernsey Finance. Monica Bhatia, Head of the Secretariat of the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes… – Continue reading
There are estimated to be one million Britons living in Spain, with UK expatriates making up the largest group of European foreign nationals. Many Britons arrive with certain misconceptions around the tax and financial make-up of the country. The foreign perception of the Spanish tax system is made up of… – Continue reading
The OECD has backed Guernsey in its fight against tax haven status, describing the crown dependency’s inclusion on the European Commission’s list of top 30 non-compliant tax jurisdictions as “very surprising”. Monica Bhatia, head of the secretariat of the Organisation for Economic Cooperation and Development’s Global Forum on Transparency and… – Continue reading
Taxes covered The agreement applies to taxes on income imposed by either country. In Bahrain these are currently the income tax payable under Legislative Decree No. 22/1979 (“the Oil Tax”); in Cyprus they are income tax, corporate income tax, Special Contribution for Defence (known as SDC tax) and capital gains… – Continue reading
Oxfam, a multinational organisation, says Africa is haemorrhaging billions of dollars because multinational companies are cheating African governments out of vital revenues by not paying their fair share in taxes. This is contained in a statement issued by the organisation, interested in combating poverty, and made available to newsmen in… – Continue reading
Access to company data is vital if policymakers are to understand how changing regulatory requirements influence performance Much focus has recently fallen on the issue of tax avoidance, as research on the subject has increasingly shown that the global economy is losing out on billions of dollars to a byzantine… – Continue reading
Calcutta, July 5: Singapore and Hong Kong, with their low corporate tax rates, have started to hove into view on the radars of multinational companies that are looking to lower their tax burdens through profit shifting. Profit shifting is a perfectly legal way of moving the earnings of an MNC… – Continue reading
The MoU is designed to give some insight into the process that will be adopted by the fiscal authorities of the two countries when assessing the tax residence of a ‘person’. International investors including South African businesses already use Mauritius as their base for their growth on the continent, but… – Continue reading
The Automatic Exchange of Information is fast becoming widely recognised as the most effective instrument to fight against tax evasion. With cooperation between tax administrations being high on the agenda in the ongoing fight against tax evasion, protection of integrity of tax systems, and transparency processes seem to be infiltrating… – Continue reading
ARBADOS’ CONTROVERSIAL BLACKLISTING by a group of European Union (EU) countries is “hypocritical” and “grossly discriminatory”, says outgoing Barbados International Business Association (BIBA) president Connie Smith. But Smith also thinks the time is right for “engaging in bilateral discussions which could hopefully conclude in double taxation agreements and bilateral investment… – Continue reading
On 12 June 2015, Insurance Europe published its comments on the permanent establishment (PE) status aspects of the draft Base Erosion and Profit Shifting Action Plan (published by the Organisation for Economic Cooperation and Development (OECD) in May 2015). The draft Action Plan aims to address weakness in the international… – Continue reading
On June 24, 2015, the World Customs Organization (WCO) published the WCO Guide to Customs Valuation and Transfer Pricing (the Guide). The primary purpose of the Guide is to assist customs officials in understanding the relationship between customs valuation and transfer pricing. However, the WCO also recommends members of the… – Continue reading
On June 8th 2015, the OECD released a new package of measures for the implementation of a new Country-by-Country (CbC) reporting plan developed under the OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS) Project, aimed at improving transparency in international tax matters. The CbC reporting plan was founded… – Continue reading
Premier Li Keqiang has strengthened China’s cooperation with the Organization for Economic Cooperation and Development (OECD) after he signed two agreements with the international economic organization in Paris on Wednesday. China has also been officially made a member of the Development Centre of the Organization for Economic Cooperation and Development… – Continue reading
Georgia’s capital Tbilisi will host dozens of top officials including members of the G20 at a special meeting in October to discuss tax avoidance strategies on national tax bases. A group of delegates from 30 countries from Eastern Europe, Central Asia and the EU are due to take part in… – Continue reading
Ireland’s attractively low rate of corporate taxation is once again under pressure with the recent release of the European Commission’s new action plan to tackle tax avoidance. The commission has been prompted into this politically ambitious move by public outcry over big, usually American, companies avoiding tax in the EU…. – Continue reading
Multinational pharmaceutical companies are unable to assure Australians they are not being “ripped off” on the price of medicines as a result of their complex global supply chains. The Australian heads of nine of the biggest global drug suppliers were forced into the embarrassing admission on Tuesday after backing themselves… – Continue reading
OECD and G20 Action Plan on Base Erosion and Profit Shifting (BEPS) was adopted in 2013. It consists of 15 actions including transfer pricing, taxation of controlled foreign corporations (CFC), digital commerce, hybrid instruments, international information exchange, tax treaty shopping etc. In 2013, OECD working group prepared draft documents regarding… – Continue reading
Action 3 of the OECD’s Base Erosion and Profit Shifting (BEPS) agenda promised to address how countries could use controlled foreign corporation (CFC) rules to combat BEPS. Unfortunately (or fortunately, depending upon one’s vantage point), as is pretty much universally agreed, the OECD’s draft report on CFC rules (the “draft”)1… – Continue reading
The next step for all Irish entities which are classified as Financial Institutions (“FIs”) for FATCA purposes is to submit a return (the “FATCA Return”) to Irish Revenue setting out details of any US reportable accounts they may have maintained during the 2014 calendar year, or to confirm by way… – Continue reading
The next step for the Cayman Islands in relation to international tax cooperation is the implementation later this year of the OECD Common Reporting Standard (CRS). The CRS standardises the global automatic exchange of information (AEOI) for tax purposes. Financial Services Minister Wayne Panton said the CRS will further strengthen… – Continue reading
The German government has announced plans to incorporate Action 13 (guidance on transfer pricing documentation and country¬by¬country (CbC) reporting) of the OECD’s BEPS project into local legislation. The wording of the new law is being drafted and may be published some time in autumn of this year. It is the… – Continue reading
On 23 June 2015, Mauritius signed the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Mauritius has taken a significant step to enhance its exchange of information legal framework. It is the seventh member of the African Tax Administration Forum to join the Convention and becomes the 87th… – Continue reading
On 1 July 2015, the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters entered into force in Russia. The Agreement was signed by Russia on 3 November 2011. The agreement is designed to facilitate international co-operation among tax authorities to improve their ability to tackle tax evasion and… – Continue reading
OECD common reporting standard On 3 June 2015, the Treasurer announced that Australia had signed the Organisation for Economic Co-operation and Development’s (OECD) common reporting standard (CRS) Multilateral Competent Authority Agreement which enables automatic exchange of CRS information between countries. Australia proposes to implement the CRS from 1 January 2017,… – Continue reading
Vaduz (ots / IR) – The government has decided in your meeting of 30 June 2015 to open negotiations on a double taxation agreement with the Principality of Monaco. As a basis for understanding the OECD Model Convention serves. The agreement should also include a clause on exchange of information… – Continue reading
The British Virgin Islands (BVI) maintains its popularity as the jurisdiction of choice for international business companies by ensuring it is at the forefront of corporate legislation and international cooperation. The popularity of BVI companies continued unabated in 2014, with incorporations of approximately 60,000 new business companies during the year;… – Continue reading
June 30 — Taxpayers continue to wrestle with big questions a year after the Foreign Account Tax Compliance Act opened for business. Acknowledging that the Internal Revenue Service is doing its best to implement a complex law, issues still remain as the reach of FATCA goes global, practitioners told Bloomberg… – Continue reading
The European Commission has released a working paper that looks at how significant the introduction of the modified nexus approach will be for the tax affairs of multinational companies that use patent box regimes Entitled Patent Boxes Design, Patents Location, and Local R&D, the paper suggests “that in the majority… – Continue reading
A common mistake when analyzing the tax implications of a cross border transaction is to jump too quickly to the ramifications of a tax treaty without first having a clear handle on the tax implications under the Income Tax Act (Canada) (“ITA”). A related issue is that even though a… – Continue reading
Insurance and financial advisors are being reminded that they will be in the position from time to time to defend Barbados’ reputation as a ‘fine jurisdiction’ in the area of international and financial services, reports the Barbados Advocate. This was pointed out by Minister of Foreign Affairs and Foreign Trade,… – Continue reading
Switzerland’s private banks are close to ridding themselves of undeclared European accounts, a salutary process but one which has undermined efforts to grow their businesses. Following the financial crisis, cash-strapped governments chased accounts hidden at banks in Zurich, Geneva and Ticino where wealthy Europeans had taken advantage of Switzerland’s famous… – Continue reading
“THE decision by a group of European Union (EU) Member States to blacklist Barbados as being non-cooperative and further claim that Barbados and 29 other countries, mostly small islands, do not meet its standards of transparency, exchange of information and fair tax competition, is hypocritical and on the face of… – Continue reading
The accusation that Hong Kong is a tax haven is unfounded and unfair, says Secretary for Financial Services and the Treasury Ceajer Chan Ka-keung. Chan wrote in his blog that the European Commission should review its inclusion of Hong Kong in the list of non- cooperative tax jurisdictions in mid-June…. – Continue reading
Multinational drug companies are presenting a united front ahead of their appearance at the Senate’s corporate tax avoidance inquiry, insisting they are honest, ethical and pay their fair share of tax. Nine pharmaceutical companies, which between them receive billions of dollars in taxpayer-subsidised sales via the Pharmaceutical Benefits Scheme, will… – Continue reading
The Italian Supreme Court has ruled that transfer pricing adjustments applied by the tax authorities may be deemed legitimate even if they have been applied after a comparison between the transactions assessed and the ones carried out by and among third independent parties. In the case at issue, the tax… – Continue reading
ATHENS, June 25 (Reuters) – When Greece’s tax police squad raided a busy cafe-restaurant in an upscale central Athens district earlier this year, it discovered two cash registers and an elaborate system of issuing fake receipts — at least 15,000 of them, over four years. Four months later, the cafe… – Continue reading
Ahead of Dublin visit, health expert discusses fighting poverty and sharing prosperity. “The Koreans have a saying that you bury your spouse in the ground but you bury your children in your heart,” said Dr Jim Yong Kim. The Korean-born health expert is speaking to The Irish Times at his… – Continue reading
A new treaty makes it more difficult for companies to take advantage of tax loopholes to avoid their financial obligations. Globally, initiatives are afoot to close tax loopholes and South Africa is one of the frontrunners – its new treaty with Mauritius removes the allure for tax-shy corporates doing business… – Continue reading
