Technology giants Apple and Google have said in their submissions to the federal inquiry into corporate tax avoidance that they support international changes to global tax rules to stop profit shifting, but have warned of the risk of Australia acting alone, saying it would cost heavily in local jobs and… – Continue reading
MUMBAI: The Mumbai bench of the tax tribunal has clarified that additional tax liability cannot be claimed from competitive industries in the name of location savings arising out of the country’s low-cost manufacturing base. The ruling may benefit pharmaceutical, auto, IT and IT-enabled companies, among others, that are engaged in… – Continue reading
Korean Gov’t to Tax Google, Facebook Like Domestic Companies orea is moving to impose taxes on foreign ICT giants such as Google, Apple, and Facebook. To this end, Ruling Saenuri Party lawmaker Hong Ji-man tabled revisions to the Income Tax Act and the Corporate Tax Act in December last year…. – Continue reading
Google has told the Australian parliament that it would prefer issues around taxation of multinational corporations to be dealt with by the G20 or the Organisation for Economic Co-operation and Development (OECD), rather than have individual countries attempt to go it alone. The Australian government is attempting to tackle profit… – Continue reading
The Confederation of British Industry (CBI) has warned the UK Government that significant changes are needed to its proposed diverted profits tax legislation, to ensure that the regime does not capture genuine commercial arrangements. In his 2014 Autumn Statement, Chancellor George Osborne announced plans to levy a 25 percent diverted… – Continue reading
On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would impose (i) a minimum tax on the current foreign earnings of U.S. corporations and their controlled foreign corporations (CFCs) and (ii) a one-time 14%… – Continue reading
The government is planning to devolve power over the corporation tax rate to the Northern Ireland assembly. This bold and unprecedented move is intended to enable Northern Ireland to compete with the Irish Republic’s headline rate of 12.5%, and follows the agreement that Scotland should set its own rate for… – Continue reading
In 2014, China continued to develop its taxation system affecting domestic and crossborder transactions. This “Legal Flash – Special Edition 2014” highlights the most significant tax updates of the year. Please see our monthly legal flashes for more information and analysis here. Taking a step-forward on anti-avoidance provisions, the State… – Continue reading
Progress continues to be made in the BEPS project, with the release in September 2014 of the “2014 Deliverables” and a raft of discussion drafts published during the autumn. Here is a summary of all the recent developments. Within the framework of the BEPS (Base Erosion and Profit Shifting) action… – Continue reading
Ireland has been ranked among the least complex business destinations for multinationals, and its appeal has improved as a result of recent international tax policy changes, according to a new study. The study from the TMF Group ranked 81 jurisdictions across Europe, the Middle East, Africa, Asia-Pacific, and the Americas… – Continue reading
Business industry feedback on BEPS discussion drafts, including comments from BIAC, TEI, Reed Elsevier, Volvo and Siemens, suggests that the OECD has done little to quash taxpayer concerns over double taxation and dispute resolution. The OECD’s BEPS project was the TP topic of 2014 and will undoubtedly retain the top… – Continue reading
Weak governance means Africa loses more than $50bn each year in unpaid taxes and money laundering, a new report has found. The analysis, published jointly by the African Union and the United Nations Economic Commission for Africa, concluded that a lack of financial transparency and difficulties in obtaining systematic data… – Continue reading
New Delhi: Multinational companies operating in India will soon have to disclose details of their operations at the country of residence and their revenue income to the Income Tax authorities. The Budget for 2015-16 may contain provisions relating to the Global Base Erosion and Profit Shifting (BEPS) rules, which are… – Continue reading
NEW DELHI: Multinational companies operating in India will soon have to disclose details of their operations at the country of residence and their revenue income to the Income Tax authorities. The Budget for 2015-16 may contain provisions relating to the Global Base Erosion and Profit Shifting (BEPS) rules, which are… – Continue reading
According to an estimate by the European Commission, the EU is at least 1,000 billion euros out of pocket because of tax evasion and avoidance. A major problem related to tax evasion is that in many cases it does not involve any illegal activities but is regarded as tax planning… – Continue reading
The present French Tax Update will focus on (i) the most salient features of the new double tax treaty signed by the People’s Republic of China (China) and France on November 26, 2013 (New DTT), (ii) the new double tax treaty signed by Singapore and France on January 15, 2015,… – Continue reading
IN LAST WEEK’S column we talked about the OECD’s BEPS Action Plan on Hybrid Mismatch Arrangements. This week’s column focuses on the OECD’s Action Plan on Harmful Tax Practices (HTP). As the world economy continues the process of globalization and technological advances, tax authorities from various jurisdictions are inevitably faced… – Continue reading
A double tax treaty (“DTT”) was signed between Cyprus and Lithuania in June 2013. The treaty which follows the OECD Model Convention for the avoidance of Double Taxation on Income and on Capital has been ratified by the two Contracting States and has entered into force as of 1 January… – Continue reading
The Government of Spain has announced that new country-by-country (CbC) reporting obligations will be effective in Spain for tax periods beginning on or after January 1, 2016. The CbC reporting obligation, which was announced on January 20, 2015, will technically apply from 2017, when tax returns for the previous year… – Continue reading
Cash reserves held outside the US for tax reasons by US multinationals are “likely to fuel a big increase in M&A activity over the next year”, said Eloise Walker a tax expert at Pinsent Masons, the law firm behind Out-law.com.30 Jan 2015 Corporate Tax Corporate tax International tax M&A Advanced… – Continue reading
Santo Domingo.- Internal Taxes Agency director Guarocuya Felix on Thursday warned that Dominican Republic must soon dismantle the barriers which limit the automatic access to information of the financial sector’s taxpayers, because despite the Arbitration Court resolution to break banking secrecy when the tax administration so requires, the information doesn’t… – Continue reading
Hong Kong’s Government should use greater-than-expected revenue receipts to implement measures to enhance the city’s international competitiveness in the 2015/16 Budget, according to a KPMG survey of senior Hong Kong-based business executives. It is foreseen that the Government will be in a position of increased fiscal strength at the end… – Continue reading
ARLINGTON, Va., Jan. 28, 2015 /PRNewswire-USNewswire/ — Bloomberg BNA today announced that its Global Transfer Pricing Conference: Paris, held in conjunction with Baker & McKenzie and in association with the Tax Management Education Institute, will occur on March 30-31 immediately after the Organisation for Economic Co-operation and Development (OECD) Global… – Continue reading
A double tax treaty (“DTT”) was signed between Cyprus and Lithuania in June 2013. The treaty which follows the OECD Model Convention for the avoidance of Double Taxation on Income and on Capital has been ratified by the two Contracting States and has entered into force as of 1 January… – Continue reading
Almost every day brings new evidence that the era of bank secrecy for tax evaders using Swiss and “offshore” bank accounts in “tax havens” is over. Both tax authorities and banks are clamping down on unreported offshore accounts. Early in 2014, Swiss bank Credit Suisse agreed to pay fines of… – Continue reading
Jan. 23 — The growth of global tax transparency is expected to leap ahead in 2015—meaning companies, individual taxpayers and financial institutions must exercise new levels of caution, practitioners told Bloomberg BNA. With more than 100 intergovernmental agreements under the Foreign Account Tax Compliance Act and dozens of countries signing… – Continue reading
Tax avoidance costs developing countries billions every year. So this week 16 domestic and internationally focused organisations have joined forces to launch a campaign for a Tax Dodging Bill. When I mention in the course of a conversation that I work for an international development charity, I often get an… – Continue reading
On 11 November 2014, the UK and German governments issued a joint statement on proposals for new rules for preferential intellectual property (IP) regimes within the G20/OECD base erosion and profit shifting (BEPS) project. Germany currently does not have a special regime for Patent Boxes, but suffers from structures that… – Continue reading
The chairman of BIAC’s tax committee, Will Morris, made an address to the OECD’s consultation on dispute resolution last week and said success on the dispute resolution action item is crucial to the overall success of the BEPS project as a whole. His comments to the OECD are as follows:… – Continue reading
Businesses have made their feelings clear about the OECD’s work on preventing treaty abuse, which is a sub-section of the organisation’s work on base erosion and profit shifting (BEPS). Comments made in an address to the OECD by Will Morris, chairman of BIAC’s (business advisory arm to the OECD) tax… – Continue reading
This edition of the Tax-News monthly feature takes in noteworthy events in the international tax arena, including attempts to inject new life into the campaign for comprehensive tax reform in the United States, and developments in the areas of free trade, indirect taxation, BEPS and tax transparency and compliance. US… – Continue reading
IN THIS second installment of the series on Base Erosion and Profit Shifting (BEPS) 2014 deliverables, we will discuss the recommendations of the Organization for Economic Co-operation and Development (OECD) on how to neutralize the effects of Hybrid Mismatch Arrangements. A Hybrid Mismatch Arrangement refers to an arrangement whereby companies,… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) is a new chapter in the US Internal Revenue Code. Chapter 4 was added by the Hiring Incentives to Restore Employment (HIRE) Act. It seeks to identify US taxpayers having accounts at foreign financial institutions (FFIs) and attempts to enforce reporting of those… – Continue reading
The governor of the Bank of England has said powerful technology firms are among those who take advantage of international tax deals. Mark Carney said: “The amount of tax that’s actually paid by technology companies is very small relative to the returns.” He was speaking at a BBC-hosted debate at… – Continue reading
Lobby groups representing Google, Amazon and other powerful US tech multinationals have launched a fierce attack on global plans to stamp out artificial corporate structures used to avoid tax. In responses to the latest stage of a two-year, G20-led programme of international tax reform, lobbyists for the US tech industry… – Continue reading
Leading regulatory supervision software provider adds new features to provide a robust, future-proof FATCA & AEOI system. Ottawa, Canada (PRWEB) January 22, 2015 Vizor, the leading regulatory supervision software provider, today introduced new features that help Tax Authorities meet their Foreign Account Tax Compliance Act (FATCA) obligations as well as… – Continue reading
In the first of this two part article, we outlined what businesses must do to comply with India’s transfer pricing laws, while stressing the key reforms introduced by the new government to bring certainty to the domestic tax system. Here, we discuss if and how India should respond to the… – Continue reading
Prepared to take tax evaders to court. The Australian Tax Office has investigated 25 international technology companies over the past 18 months for tax avoidance as part of its ongoing crackdown on elaborate cross-border tax structures and profit shifting. The federal government late last year gave the ATO extra resources… – Continue reading
To comply with unconstitutional pseudo-treaties negotiated by the Obama administration without the consent of Congress or any semblance of constitutional authority, the IRS announced that it will be sharing private financial information on U.S. bank account holders with foreign powers. No warrant is needed for foreign governments or tyrants to… – Continue reading
Lobbyists representing firms including Google, Amazon and Apple claim ‘fundamental flaws’ in G20-led reforms The World Economic Forum in Davos, where Google, Microsoft and Facebook executives will discuss the digital economy on Thursday. Photograph: Fabrice Coffrini/AFP/Getty Images Lobby groups representing Google, Amazon and other powerful US tech multinationals have launched… – Continue reading
The Davis Committee has made certain recommendations relating to transfer pricing and documentation in its report on the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan. We are aware that the current transfer pricing practical guidelines, as contained in SARS’ Practice Note 7 (PN7), are not that clear and… – Continue reading
On October 29, 2014, through the OECD “Global Forum on Transparency and Exchange of Information for Tax Purposes,” both the OECD and G20 countries endorsed a new Standard for Automatic Exchange of Financial Account Information in Tax Matter. 59 countries are so-called “early adopters” and are committed to undertaking their… – Continue reading
In December 2014, the Canada Revenue Agency (CRA) issued a letter to a sample of taxpayers to remind them of the criteria for filing a T1135-Foreign Income Verification Statement and to review their income tax filings to ensure they have been properly reporting the relevant assets and income. All Canadian… – Continue reading
For as long as leaders from low-income countries are excluded from the solution, tax avoidance will inflict costly and sometimes life-threatening consequences on millions of individuals Politicians have been all-too-eager to label 2014 a milestone year for action on tax avoidance, with many of the world’s leading economies having introduced… – Continue reading
Both the OECD and the EU are exploring options to change how digital businesses are taxed, while NGOs are stepping up their pressure on tax authorities to challenge large companies’ transfer pricing arrangements. No matter how robust your digital business’s transfer pricing arrangements appear to have been in the past,… – Continue reading
Outlook: The OECD’s work on corporate tax avoidance has proceeded at a faster rate than many expected According to Oxfam, on current trends the richest 1 per cent of the world’s population will have a greater share of its wealth than the remaining 99 per cent within two years. The… – Continue reading
Costa Rica’s going under the magnifying glass for the next two weeks as international money laundering experts comb through the country’s books. President Luis Guillermo Solís declared the audit from the Financial Action Task Force of Latin America (GAFILAT) a subject of national interest in Monday’s edition of the official… – Continue reading
After almost three years’ negotiations over untaxed Italian assets in Swiss banks, Switzerland and Italy have reached an agreement in principle on future cooperation in tax matters. The agreement between Switzerland and Italy was initialled on 19 December 2014 The two governments are currently preparing the signature of a Protocol… – Continue reading
Observers of offshore financial centres will know that post 2008 they have been weathering a perfect storm. Firstly, reduced transactional flows, simply because there is less money available for structured finance and investment generally. Secondly, a constant barrage of negative publicity, which deliberately seeks to conflate tax evasion and tax… – Continue reading
Since the introduction of the Transaction Value System of customs valuation by Canada on January 1, 1985, the Canada Border Services Agency (CBSA) has maintained a stated policy of denying refund claims of related party importers who seek to amend declared values for duty to account for adjustments that decrease… – Continue reading
