CRA recently released a new Transfer Pricing Memorandum (TPM-15) giving detailed guidance on CRA’s audit approach to management fees and other charges for intra-group services, including on allocation keys for indirect chargebacks and markups on costs. The document expands considerably upon brief guidance on this topic in CRA’s main Information… – Continue reading
Pact on information exchange in tax treatment Paris, February 25 – An important tax treaty signed between Italy and Switzerland is evidence of the “change of a crucial paradigm,” in banking secrecy with global implications, Pascal Saint-Amans, director of the center for tax policy and administration at the OECD told… – Continue reading
Thanks in part to past concerns that globalization could lead to double taxation, corporations have numerous techniques at their disposal to reduce their tax bills, including the placement of subsidiaries and spinoff holding companies in low-tax jurisdictions. The Group of 20 wants to change that. The Organisation for Economic Cooperation… – Continue reading
The government is set to make changes in the income tax rules to seek overseas operational details of multinational businesses that have a turnover of over R5,000 crore in India in order to decide which companies should be audited for income suppression, reports Gireesh Chandra Prasad in New Delhi. The… – Continue reading
Jersey’s chief minister Ian Gorst has formally expressed his “disappointment” with statements from Labour Party leader Ed Miliband about tax transparency and disclosure efforts by UK overseas territories. In an open letter to the Opposition leader, Gorst said the Island government had reiterated “many times” in past discussions with the… – Continue reading
The government has been able to instil a positive sentiment in the country. Various policy initiatives like Make-in-India, aimed to make India a manufacturing hub, and the Clean India campaign; updating age-old laws and tweaking the Goods and Services Tax to a more acceptable form, introducing greater clarity in the… – Continue reading
São Paulo, Brazil. International transfer pricing is able to take place in Brazil, outside of the OECD While Brazil is not a member of the OECD, many multinational groups there are able to successfully navigate international transfer pricing standards, yielding effective results The economic view of Brazil has always been… – Continue reading
Transfer pricing policy in the United States is guided by Section 482 of the Internal Revenue Code (and by the Organization for Economic Cooperation and Development under its Base Erosion and Profit Shifting initiative), and its application is not limited to cross-border transactions. In fact, some states, such as New… – Continue reading
Attempt to plug every gap makes the system unworkable – Norton Rose Fulbright. JOHANNESBURG – A tax expert has warned against over-complicating tax legislation in an attempt to block every loophole or perceived underpayments of tax, as it makes the tax system “unworkable”. Andrew Wellsted, director at Norton Rose Fulbright,… – Continue reading
When I consider what’s likely to have the most impact in tax this year, I keep coming back to the massive shift in attitude by tax authorities in the aftermath of the Global Financial Crisis (GFC). Usually changes in the tax world are incremental, but what is going on now… – Continue reading
Switzerland and neighbouring Italy have revised a double taxation agreement which includes provisions for the exchange of information in line with the standards of the Organisation for Economic Development and Co-operation (OECD). The accord and a roadmap for the amendment of tax rules on cross-border workers as well as improved… – Continue reading
Switzerland and neighbouring Italy have revised a double taxation agreement which includes provisions for the exchange of information in line with the standards of the Organisation for Economic Development and Co-operation (OECD). The accord and a roadmap for the amendment of tax rules on cross-border workers as well as improved… – Continue reading
According to Peter Willey, EY’s Channel Islands Head of Tax, the Channel Islands are likely to be impacted by decisions being made now in other jurisdictions. EY recently surveyed its tax policy leaders in 32 jurisdictions to ask them to forecast the tax policy outlook for 2015 in their jurisdiction…. – Continue reading
UK, US, Australia, Brazil, India- governments of developed and developing countries are battling profit shifting by MNCs such as Amazon, Google, Apple and Starbucks. The allegation- MNCs are shifting profits to jurisdictions where there is little or no tax to be paid. The solution- OECD’s BEPS action plan which, among… – Continue reading
The economic downturn across the world and rising public debt seems to have led various governments, globally, to focus on curbing erosion of the tax base by shifting profits to overseas jurisdictions. Several revenue authorities, globally, were of the view that companies have structured their intra-group contractual arrangements in a… – Continue reading
Caterpillar, Inc. (CAT), the heavy equipment maker is now under scrutiny as the IRS now demands $1 billion in taxes and penalties. This should come as no shock after the company faced Senate scrutiny in 2014 over its tax plans. Tax Woes The company deals in the designing, manufacturing and… – Continue reading
On 17 July 2013 the Minister of Finance appointed a tax review committee, headed by Judge Dennis Davis (the “Davis Committee”) to make recommendations for possible tax reforms in South Africa (“SA”). The Davis Committee was required to take into account recent international developments and, in particular, to address concerns… – Continue reading
The Government of India brought in a retrospective amendment in 2012 to nullify the Supreme Court judgement in the case of Vodafone International Holdings B.V. to tax capital gains arising from transfer of shares or interest in a foreign company deriving its value ‘substantially’ from Indian assets. However, the Government… – Continue reading
A fresh drive by the European Commission to ensure companies pay their tax where they make their profits could have far-reaching consequences for Irish corporate tax revenue. Some new pieces of legislation will be presented over the next few months, but one of the biggest could be the revival of… – Continue reading
The European Commission launched its work on its ambitious agenda to combat tax avoidance and aggressive tax planning. The College of Commissioners held a first orientation debate on possible key actions to ensure a fairer and more transparent approach to taxation in the EU.President Jean-Claude Juncker has made the fight… – Continue reading
Growing trend of chasing ‘high net worth foreign nationals’? Cooperation between HM Revenue and Customs (HMRC) and foreign tax authorities will only increase as more countries sign up to automatic tax information exchange agreements. This is according to Pinsent Masons, the law firm behind Out-Law.com, which obtained figures showing a… – Continue reading
NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance Act in 2010. In the past five years, more than 10,000… – Continue reading
The abolition of unfair taxes was one of the foundational principles of Magna Carta, a document that King John assented to on June 15, 1215 at Runnymede, England. Taxation must be fair, and requires the consent of the people. There is no more unfair aspect of fiscal law than retroactive… – Continue reading
The Government may have retreated on its promises to crack down on multinational IT companies avoiding tax, but the Australian Tax Office says it’s on the case. Less than a year ago the ATO appointed Andrew Mills, a tax lawyer from outside the government bureaucracy, to the important role of… – Continue reading
Every acquisition requires careful tax planning early on in the process, especially when dealing with cross border acquisitions. One important consideration when a foreign company plans to acquire a Canadian company is the impact of any tax treaties that currently exist between the two jurisdictions. Tax treaties effectively reduce tax… – Continue reading
The Manx government will not officially respond to Labour leader Ed Miliband’s ultimatum on beneficial ownership. Mr Miliband has threatened to place on an international blacklist any Crown Dependency or British Overseas Territory that fails to produce a public register of company beneficial ownership within six months of Labour coming… – Continue reading
Some of the biggest listed Irish firms have subsidiaries in so-called ‘tax havens’, like the British Virgin Islands, Jersey or Luxembourg. They say it’s not to reduce their tax bills – so why are they there? The subsidiaries are registered in well-known offshore tax havens, such as the British Virgin… – Continue reading
Budget should issue a) rules for announcements that were made in the budget in July 2014, (b) clarifications and guidance on matters that were at the centre of controversy during the past few years like equity infusion, valuations, etc. and (c) tax administrations, infrastructure and approach. The new government in… – Continue reading
The UK Treasury Committee has said that the draft legislation on the diverted profits tax (DPT) is unwieldy and stressed that the Government’s unilateral policy response should not destabilize international tax reform efforts. The Committee’s response to the plans are included in its new report on the Autumn Statement 2014,… – Continue reading
If the Davis tax committee’s recommendations are followed, tax avoidance could be effectively reined in. Zeroing in on the super-wealthy and tax reluctant remains at the top of the global agenda as budgets across the world grow increasingly hungry for extra revenues. Now a draft report from the Davis tax… – Continue reading
UN special rapporteur says loopholes and schemes damage Ireland’s reputation The United Nations special rapporteur on extreme poverty and human rights has criticised Irish tax policies which have had a negative impact on poorer and developing countries. Professor Philip Alston has said loopholes and schemes introduced by successive governments have… – Continue reading
NEW DELHI: The much-feared general anti avoidance rules (GAAR) could be deferred by about two years so that business sentiment is allowed to improve in India but will need to be rolled out in some form or the other by 2017, in sync with the international framework on preventing treaty… – Continue reading
The International Chamber of Commerce (ICC) has released the 2015 update of its policy statement on “Transfer Pricing and Customs Valuation” first issued in 2012. The statement supports companies that face the challenge of determining the appropriate related party valuation of goods in the context of disparity between governments’ customs… – Continue reading
“Well, Jon, the Government’s about to bring in a 1.5% corporate, or company, tax cut from the 1st of July. That’s something that obviously we support, because (the) corporate tax rate at 30% is not competitive with the rest of the region and we need to drive that down.” –… – Continue reading
Island’s History of Robust Regulation, Rule of Law, Global Tax Treaties and Lack of Bank Secrecy Laws Ought to be Recognised by UK Labour Party HAMILTON, Bermuda, Feb. 10, 2015 (GLOBE NEWSWIRE) — Bermuda’s well-documented financial services regulation, international partnership treaties, and lack of bank secrecy legislation ought to be… – Continue reading
Bermuda’s well-documented financial services regulation, international partnership treaties, and lack of bank secrecy legislation ought to be recognised by the UK Labour Party, the Bermuda Business Development Agency (BDA) said today. The BDA echoed the Bermuda Government’s weekend response to UK Opposition Leader Ed Miliband following a warning letter issued… – Continue reading
A majority of CFOs at multinational corporations believe that publicity about their tax-planning strategies is having a negative impact on the reputation of their companies, according to a new poll. The survey, by the tax advisory firm Taxand, found that 77 percent of the CFOs polled said that exposure to… – Continue reading
The latest FATCA Foreign Financial Institutions (FFI) list reveals that of the top five countries with the most registrations to date, the Tax Authorities of two – the Cayman Islands and the British Virgin Islands – are implementing the Vizor for FATCA & AEOI Vizor Software, the leading regulatory supervision… – Continue reading
The Irish Finance Department and the Economic and Social Research Institute (ESRI) are to jointly run a two-year research program covering macroeconomic and tax policy issues. Under an agreement signed by the Department and ESRI, researchers from the Institute will work alongside officials from the Department on various research projects…. – Continue reading
On February 6, 2015, the Organisation for Economic Co-operation and Development (OECD) announced that it has reached agreement with the Group of Twenty (G-20) Finance Ministers on three key elements of its base erosion and profit shifting project. The three elements, which the OECD said will enable implementation of the… – Continue reading
LONDON, England — A Labour government would push for UK overseas territories to be put on an international blacklist if they refuse to co-operate with a drive against tax avoidance, Labour Party leader Ed Miliband has told them ahead of general elections in Britain in May. In a letter to… – Continue reading
Switzerland and Liechtenstein have concluded negotiations toward a new double tax agreement (DTA), which should enter into force from January 2017. Switzerland’s Federal Department of Finance (FDF) announced on February 5, 2015, that talks concluded on February 2. The FDF expects the deal to be signed this summer and, pending… – Continue reading
The Department of Finance recently published the attached public consultation on the ‘Knowledge Development Box’ (“KDB”), inviting submissions before 8 April 2015. This regime was widely publicised in connection with the 2015 Budget and is intended to play a key role in Ireland’s corporate tax regime, as outlined in the… – Continue reading
The Organization for Economic Co-operation and Development’s (OECD) Action Plan 6 on the Base Erosion and Profit Shifting (BEPS) initiative recognizes that countries need to incorporate sufficient safeguards in their tax treaties and domestic rules to protect against practices that take advantage of the differences in national tax systems and… – Continue reading
As countries share more information, opportunities to squirrel away cash abroad will continue to narrow AMONG the sins that have most angered the austerity-weary everywhere is the use of undeclared offshore accounts to stash the wealth of the rich. Greeks were particularly enraged when data stolen from Swiss banks showed… – Continue reading
A Labour government would push for UK overseas territories to be put on an international blacklist if they refuse to co-operate with a drive against tax avoidance, Ed Miliband has told them. In a letter to their leaders, he said they would have six months to compile a public register… – Continue reading
The OECD will present the latest developments in the OECD/G20 project to combat base erosion and profit shifting (BEPS) by multinational enterprises during a G20 Finance Ministers meeting on early next week (9th/10th February) in Istanbul. OECD and G20 countries have agreed three key elements that will enable implementation of… – Continue reading
A swath of changes to corporation tax in the European Commission’s pipeline topped the Taoiseach’s agenda when he met the president of the European Commission, Jean Claude Juncker officially in Brussels. New rules that would force every country to make public the tax arrangements with larger companies, including multi nationals… – Continue reading
The Public Accounts Committee (PAC) has launched an attack on the tax industry in the light of evidence presented by Big Four firm PwC In a 17-page report on tax avoidance and large accountancy firms, the PAC blasts the tax industry as being unable to regulate itself and calls on… – Continue reading
The European Commission is currently conducting in-depth investigations into whether national tax rulings breach the EU’s competition rules. Whilst the spark for these investigations was the “Luxleaks” scandal, in December 2014 the Commission sought information from all Member States as part of a much larger campaign to attack what the… – Continue reading
