Category: OECD

OECD Charts States’ Participation In Int’l Tax Initiatives

For the first time, the OECD has published a map that sets out countries’ participation and compliance with international tax initiatives, looking specifically at the exchange of information in tax matters, with the old international standard – the exchange of information on request – and the new, on the automatic… – Continue reading

‘EU Decision Demonstrates Bermuda’s Position’

[Updated] The Government of Bermuda said they note that the Economic and Financial Affairs Council [ECOFIN] has “reaffirmed Bermuda’s status as a cooperative tax jurisdiction.” Premier David Burt said, “Once again the EU has recognized Bermuda’s status as a cooperative jurisdiction, despite the interest surrounding a hack on a global… – Continue reading

New Paper Looks At How To Support Developing States On BEPS

The International Centre for Tax and Development has released a working paper on how to best support developing countries in the area of taxation. The paper says that developing countries would particularly benefit from support in the implementation of two areas that were covered by the OECD’s base erosion and… – Continue reading

OECD Releases First Peer Reviews On Tax Ruling Info Exchange

On December 2, the OECD released the first analysis of individual countries’ progress in spontaneously exchanging information on tax rulings in accordance with Action 5 of the BEPS package of measures released in October 2015. The first annual report on the exchange of information on rulings evaluates how 44 countries,… – Continue reading

Bahamas ‘Done Everything Possible’ To Avoid Blacklist

THE Deputy Prime Minister believes the Bahamas has “done everything we could possibly do” to escape the European Union (EU) ‘tax haven’ blacklist that will be issued tomorrow. K P Turnquest told Tribune Business that the Minnis administration “has no reason to think” this nation will be deemed a ‘non-cooperative… – Continue reading

South Africa, Belgium, Jersey Extend CbC Reporting Deadlines

South Africa, Jersey, and Belgium are among a handful of territories that have recently announced an extension to the due date for country-by-country reports under the new frameworks being introduced under Action 13 of the OECD’s base erosion and profit shifting Action Plan. The CbC report is one element of… – Continue reading

OECD statistics show 20% increase in outstanding tax treaty disputes involving UK

The number of outstanding tax treaty related disputes in the UK increased in 2016 by almost 20% from 262 at the beginning of the year to 314 at the end of the year, according to statistics released by the Organisation for Economic Cooperation and Development (OECD). The statistics show the… – Continue reading

OECD Issues Further Guidance On CbC Reporting

The OECD has published additional guidance on the implementation of the country-by-country (CbC) reporting requirement proposed under Action 13 of its base erosion and profit shifting (BEPS) project. The guidance, issued on November 30, addresses the following issues: how to report amounts taken from financial statements prepared using fair value… – Continue reading

Bermuda To Exchange MNE Tax Info With The UK

Bermuda and the UK recently signed an agreement providing for the automatic exchange of country-by-country reports. Bermuda is the first UK Overseas Territory to sign a CbC Competent Authority Agreement with the UK, which enables the automatic reporting of corporate income on a country-by-country basis for UK-related transfer pricing enforcement… – Continue reading

Barbados To Sign OECD Pact To Revise Its DTAs In January

Barbados says it expects to sign the new OECD BEPS Multilateral Instrument at the end of January 2018 to introduce changes to its tax treaty network to prevent base erosion and profit shifting. The “Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS)”… – Continue reading

Developing States To Receive Tax Transparency Support

The OECD’s Global Forum recently adopted a plan of action to help developing countries participate in and benefit from the automatic exchange of financial account information for tax purposes. Under the plan, developing countries have been invited to undergo a preliminary assessment of their capacity to implement the Common Reporting… – Continue reading

India to accept mutual agreement process in transfer pricing cases

NEW DELHI The Indian Income Tax Department will accept applications for Mutual Agreement Procedure (MAP) in transfer pricing disputes, as well as for bilateral Advance Pricing Agreements (APAs), even for entities resident in countries with which India has double taxation avoidance agreements (DTAA), minus the provision to claim corresponding tax… – Continue reading

Australia Extends CbC Reporting Deadline

The Australian Taxation Office (ATO) has extended until February 15, 2018, the deadline for “significant global entities” to file their country-by-country (CbC) reports. The extension applies to entities that are December and January balancers filing for the first time. The extension also applies to the filing of local and master… – Continue reading

New PPT rule in the OECD’s Multilateral Instrument to displace Canadian GAAR?

In this Update On June 7, 2017, Canada signed the OECD’s Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) The MLI will modify up to 75 of Canada’s bilateral tax treaties, including adding a broad anti-avoidance rule to these treaties (the… – Continue reading

OECD approves the 2017 update to the OECD Model Tax Convention

On November 21, 2017, the OECD Council approved the contents of the 2017 Update to the OECD Model Tax Convention. The 2017 Update primarily comprises changes to the OECD Model Tax Convention and related commentary that were developed through the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project including changes… – Continue reading

Loophole In New Global Tax Evasion Crackdown: Why An International Effort May Be Blunted

A major new global transparency measure aimed at curbing cross-border tax evasion by requiring countries to share information on the wealth of each other’s nationals could be undermined by the abuse of residency- and citizenship-for-sale schemes. Tax justice campaigners say that some of these schemes are already being marketed as… – Continue reading

EU competition chief Margrethe Vestager threatens Tech giants with tax reform

Europe’s fierce enforcer of competition rules is threatening tech giants with tough new rules on tax if politicians fail to come to an agreement on changes to the current system. Efforts to amend rules that would apply tax more fairly to firms which largely operate online such as Google, Amazon,… – Continue reading

Irish Revenue Launches New Tax Evasion Inquiry

The Irish Revenue has announced that a new inquiry is underway to identify and pursue taxpayers engaged in offshore tax evasion and avoidance. Revenue said that the inquiry is being conducted in the context of increased and ongoing sharing of information between tax administrations, and of the changes to voluntary… – Continue reading

Isle of Man complies with international standards

The Isle of Man’s critics ignore the great progress it has made in keeping its business above board. Last week the island received a ringing endorsement from the OECD. We have retained the top ’compliant’ rating by the global body reviewing tax transparency – one of only six countries worldwide…. – Continue reading

Canada, Antigua And Barbuda Sign TIEA

Canada and Antigua and Barbuda have signed a new tax information exchange agreement. The agreement was signed on October 31, the Canadian Government announced on November 14. Negotiations were launched in November 2010. The agreement provides for the mutual exchange of tax information that is possessed by, or is accessible… – Continue reading

Virtual Currency Exchanges and US Customers Beware, IRS is Coming: Expert Blog

In the aftermath of Satoshi Nakamoto’s groundbreaking paper in 2009, money began travelling via a new financial route – virtual currencies. The first Bitcoin exchange was established on February 6, 2010 where Bitcoin traded for the first time for 0.3 cents. Last June, the American Institute of Certified Public Accountants… – Continue reading

Qatar Commits Support To All Of The OECD’s Tax Work

Qatar has become the 115th jurisdiction to sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. The Convention is touted by the OECD as “the most powerful instrument for international tax cooperation.” It provides for all forms of administrative assistance in tax matters: exchange of information on request,… – Continue reading

Bahamas Must ‘Get Across Line’ On Tax Automatic Exchange

THE Government has been urged to “get across the line before year-end” on global tax information exchange standards, amid hope the relevant legislation will reach Parliament tomorrow. Michael Paton, a former Bahamas Financial Services Board (BFSB) chairman, told Tribune Business that the Bahamas needed to upgrade its existing legislation to… – Continue reading

Bulgaria Requires CbC Reports By Year End

Bulgaria has said that multinationals covered by the country’s new transfer pricing country-by-country reporting regime should submit their first report by December 31, 2017. Through Order 3LIY-1410, Bulgaria’s National Revenue Agency has newly set out the rules concerning country-by-country documentation, including who the reporting obligations apply to and how to… – Continue reading

BDA & Industry Respond To Paradise Papers

“Reportage about hacked data from global law firm Appleby has highlighted the substantial lack of media understanding of offshore investment structures and Bermuda’s long-time reputation for tax transparency and cooperation with international authorities,” the Bermuda Business Development Agency said. “Bermuda is committed to the exchange of relevant information to legitimate… – Continue reading

PANA report ‘confirms’ Malta ‘not a tax haven’

FinanceMalta, the Institute of Financial Services Practitioners, the Chamber of Commerce, Enterprise and Industry and the Gozo Business Chamber have welcomed the PANA Committee’s confirmation that the Maltese tax system is in line with current international and EU standards. Furthermore,according to the Committee, Malta has transposed EU rules and respects… – Continue reading

CCCTB FAQ

The European Union Common Consolidated Corporate Tax Base (CCCTB) has been talked about recently as a solution to the problem of an imperfect pan-EU corporate tax system, which allows large companies, particularly those with a digital presence, to detach profits from value-creation, and pay tax in low-tax jurisdictions. But what… – Continue reading

‘Low Level’ Corporation Tax Studied

The Deputy Prime Minister yesterday revealed the Bahamas “may have to look at” implementing a low-rate corporate income tax, as global regulatory pressures force “hard decisions” upon it. K P Turnquest, while emphasising that such a move was a long way off, agreed that compliance with the OECD’s Base Erosion… – Continue reading

Treasury ratifies OECD’s tax avoidance treaty

The Treasury says the Isle of Man has become one of the first countries to sign a new international treaty against tax avoidance. The Island joins Austria in agreeing to the OECD’s Multilateral Convention to Implement Tax Treasury Related Measures to Prevent Base Erosion and Profit Shifting. The agreement aims… – Continue reading

Transfer pricing: tighter reporting norms for multinationals notified

CBDT issues final rules for Master File and Country-by-Country reporting NEW DELHI, NOV 1:  The Central Board of Direct Taxes (CBDT) has notified the final rules for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country (CbyC) report. This is largely in line with the draft… – Continue reading

Base Erosion and Profit Shifting Project implementation in Mauritius

Introduction The Organisation for Economic Co-operation and Development (OECD) is an economic organisation made up of 35 member countries, with the aim of encouraging economic progress and world trade. In 2015, the OECD developed the Base Erosion and Profit Shifting (BEPS) Project, made up of reports on 15 action plans,… – Continue reading

Intercompany Transactions: How does BEPS Change Transfer Pricing?

The OECD’s Anti Base Erosion and Profit Shifting Initiative (BEPS) significantly affects current transfer pricing regimes regarding intangibles, documentation and dispute resolution. Why is Transfer Pricing relevant for BEPS? To avoid base erosion and profit shifting of multinational companies, the OECD initiated an action plan consisting of 15 actions with… – Continue reading

Peru moves forward in tax evasion fight

Peru takes one step further in the eradication of tax avoidance and evasion after signing the Convention on Mutual Administrative Assistance in Tax Matters with the Organisation for Economic Co-operation and Development (OECD). Deputy Director of the OECD‘s Centre for Tax Policy and Administration Grace Perez-Navarro affirmed these two crimes… – Continue reading

Japan’s National Tax Agency releases guidance on requesting Mutual Agreement Procedure assistance

The Japanese National Tax Agency (NTA) has released guidance for taxpayers on the mutual agreement procedure (MAP), in line with the recommendations of the OECD’s Base erosion and profit shifting (BEPS) Action 14 Final Report. The guidance is intended to supplement the Commissioner’s Directive on the Mutual Agreement Procedures, which… – Continue reading

Oman Joins BEPS Inclusive Framework

Oman has become the latest country to agree to implement the base erosion and profit shifting minimum standards by signing up to the BEPS Inclusive Framework. In implementing the minimum standards, countries agree to remove harmful tax provisions in their domestic tax regimes, amend their tax treaty rules to prevent… – Continue reading

Bahamas Converts Finland Taxation Deal To Automatic

THE Bahamas yesterday upgraded its tax information exchange agreement with Finland to the automatic variety, as it bids to meet global standards by September 2018. K P Turnquest, deputy prime minister, signed the Protocol to Amend the Tax Information Exchange Agreement between the Bahamas and Finland, with the latter’s ambassador… – Continue reading

International information exchange system to help fight tax evasion: Slovak officials

BRATISLAVA, Oct.18 (Xinhua) — International information exchange system could help fight tax evasion, said President of Slovak Financial Administration Frantisek Imrecze at a press conference here on Wednesday. According to Imrecze, the information exchange system has been available to the Slovak Financial Administration since Sept. 30, the Slovak tax office… – Continue reading

Switzerland agrees to share tax information on multinationals

ZURICH (Reuters) – Switzerland said on Wednesday it would start sharing information on the activities of multinationals in its territory with other countries in 2020, joining an international push to fight tax evasion. The new measures will force about 200 large companies in the low-tax haven to prepare country-by-country reports… – Continue reading

NZ’s IRD a global leader in shift to digital

NZ’s IRD a global leader in shift to digital, unobtrusive tax administration, Ferguson says Oct. 18 (BusinessDesk) – The Inland Revenue Department is leading the charge in a global shift to digitally-based tax administration that’s unobtrusive and easy to use, says commissioner Naomi Ferguson. The New Zealand tax department is… – Continue reading

OECD’s Gurria Calls For Collective Action On Digital Taxation

OECD Secretary-General Angel Gurria has called for a collective effort on the design of temporary, short-term measures to tackle the international tax challenges of the digital economy. Speaking at the Group of Twenty (G-20) Finance Ministers and Central Bank Governors meeting held in Washington on October 13, Gurria said: “There… – Continue reading

Singapore tax incentives meet global standards

Republic has implemented all four agreed standards under OECD’s tax/profit project An international body overseeing global tax practices has said that Singapore’s tax incentives meet the international standards on countering corporate tax avoidance. The Forum on Harmful Tax Practices (FHTP) said in a report yesterday that it had reviewed 164… – Continue reading

CbCR obligations for Italian entity members of US groups

Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27… – Continue reading