Midlands businesses can still benefit from the Patent Box, according to international accountancy firm Mazars. It follows plans to amend it – resulting in a narrower focus on UK R&D. That is the verdict from Birmingham professionals Peter Jelfs, senior tax manager at international accountancy firm Mazars, and Nicholas Braddon,… – Continue reading
AROUND the world, large, listed companies are troubled by cyber-security risks and company taxes, yet these concerns remain fairly low on the priority list of boards of directors. According to a PwC report on nonexecutive directors’ practices and remuneration trends, 60% of directors said their board had not discussed public… – Continue reading
We commissioners have vowed to clamp down on evasion and fraud to make sure all companies pay their fair share 2014 was the year the world discovered there is no whisky in a double Irish and no cheese in a Dutch sandwich. Discussions about fair taxation and tax avoidance featured… – Continue reading
Brian Hayes: Ireland has nothing to apologise for Ireland is not a tax haven and should not allow itself to be “scapegoated” by larger European countries, Fine Gael MEP Brian Hayes has said. Ireland had nothing to apologise for and was critical of the approach taken to a number of member… – Continue reading
The International Chamber of Commerce (ICC) has reaffirmed its active engagement in the second phase of the G20 / Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project while underscoring the importance of a coordinated and consistent approach to tax law changes. ICC continues to… – Continue reading
The Swiss Government has launched a three-month consultation period on draft legislation that will pave the way for Switzerland to implement tax information sharing agreements with other countries. Finance minister Eveline Widmer-Schlumpf announced the schedule in Bern on Wednesday and explained in outline that the cabinet wants Switzerland to agree… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) information exchange network has gone live and is receiving the first reports on the financial affairs of US taxpayers. The online network links tax authorities in 110 countries and more than 145,000 financial institutions with the Internal Revenue Service (IRS). Financial institutions outside… – Continue reading
The Department of Finance is understood to be “open-minded” over what rate should be applied to its proposed ‘knowledge box’ tax regime for patents and intellectual property assets developed here. The department yesterday formally launched its planned consultation process for the programme, which was announced in October’s Budget. There has… – Continue reading
The Government has unveiled a three-month public consultation on the proposed Knowledge Development Box, with submissions invited from businesses and the wider public. The proposed scheme, also known as a patent box, was announced in the Budget and is due to come into force next year. It will provide for… – Continue reading
Ireland: The Department of Finance will publish a consultation document Wednesday on the proposed ‘knowledge box’ patent tax regime that will be enacted in replacement of the Double Dutch tax avoidance scheme. Late last year Department officials hinted that a 5% rate was under discussion to match the Dutch rate…. – Continue reading
On October 14 2014, Ireland’s Minister for Finance (the Minister) announced changes to Ireland’s corporate residence rules. Following much speculation, the Minister confirmed that Ireland would change its rules to restrict the ability of Irish incorporated companies to be treated as non-Irish resident. Under existing Irish law, an Irish incorporated… – Continue reading
Switzerland’s Financial Centre Reforms Are A Work In Progress by Andreas Keiser, swissinfo.ch In the last few months Switzerland has made progress in making its financial centre internationally compliant. Key areas are the automatic exchange of information, enhanced administrative assistance with other countries, and the reduction of foreign untaxed assets…. – Continue reading
Within the framework of the BEPS (Base Erosion and Profit Shifting) action plan, adopted in July 2013, on last September 16, the OECD published its first recommendations in the form of reports on 7 of the 15 points of the action plan: Address the tax challenges of the digital economy… – Continue reading
Luxembourg’s fund management industry has responded to proposals put forward by the Organisation for Economic Cooperation and Development (OECD) on preventing treaty abuse, with a particular focus on the treatment of collective investment vehicles (CIVs). The response, from the Association of the Luxembourg Fund Industry (ALFI), concerns proposals put forward… – Continue reading
Already on the radar of governments and regulatory bodies around the world, recent developments with respect to the Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Action Plan are raising further the profile of oil and gas companies globally with both tax authorities and the… – Continue reading
Regulators have updated guidelines regarding a little-known area of tax accounting that has become a political hot potato in recent years. Transfer pricing, as the process is called, refers to the price paid by one unit of a company to another for goods, services, intellectual property or financial transactions such… – Continue reading
British Members of Parliament (MPs) have questioned the Government’s unilateral decision to push for the introduction of a Diverted Profits Tax (DPT) ahead of the completion of the Organisation for Economic Cooperation and Development’s (OECD’s) work on base erosion and profit shifting (BEPS). In a debate held in Parliament on… – Continue reading
The UK is proposing to introduce a unilateral, non-OECD co-ordinated anti-BEPS provision, referred to in the media as the “Google Tax”, with effect from 1 April 2015. The draft provision is very complex, and it will be time consuming to assess its potential impact on many common cross-border business structures…. – Continue reading
India enacted transfer pricing rules in 2001, which require companies to conclude international transactions with associated enterprises at an arm’s length. The legislation is primarily targeted at large business groups who engage in base erosion and profit shifting to avoid paying corporate income tax in India. This article is the… – Continue reading
Countries are competing to lower their tax rates to please the corporate giants, but the result is a massive collective loss of revenue. Only international coordination can wipe out the practice and defeat the negative influence of the Big Four accounting firms. Tax havens have long existed in the popular… – Continue reading
(CS/vb) A former PwC employee could face up to 10 years in prison for leaking thousands of documents in what has become known as the LuxLeaks scandal, his lawyer has said. Informant Antoine Deltour spoke on French television station Canal+ on Tuesday, saying that among experts, tax avoidance schemes via… – Continue reading
THE South African Revenue Service (SARS) has already begun to tackle the erosion of the tax base through profit shifting, which was addressed in an interim report of the Davis tax committee that was released last month for public comment. SA loses billions of rand in revenue annually through the… – Continue reading
New research shows that 2014 saw many fundamental changes across the global tax system as governments look to reform their regimes for the long term, complying with new OECD guidelines, whilst significantly clamping down on multinationals in light of increasing public media scrutiny. The research was undertaken by Taxand, a… – Continue reading
Barbados appears to be moving into full financial information-sharing mode as the world’s most powerful countries put their foot down on tax evasion. It is already known that last November Government signed an Inter Governmental Agreement with the United States (US) to exchange information on their citizens who have thousands… – Continue reading
Controversial proposals for a law to make failing to declare offshore income a criminal offence seem to have been put on the backburner by The Treasury. Chancellor George Osborne announced the measure as part of a campaign to stamp out tax evasion as part of his Budget 2014. However, no… – Continue reading
What’s coming our with with regards to the Foreign Account Tax Compliance Act (FATCA) in 2015? 2015 sees a number of impeding developments regarding FATCA compliance as the US presses on with its quest to target tax non-compliance by U.S. taxpayers with foreign accounts. Nick Matthews, Global Head of Forensic… – Continue reading
What’s coming our with with regards to the Foreign Account Tax Compliance Act (FATCA) in 2015? 2015 sees a number of impeding developments regarding FATCA compliance as the US presses on with its quest to target tax non-compliance by U.S. taxpayers with foreign accounts. Nick Matthews, Global Head of Forensic… – Continue reading
Multinational enterprises (MNEs) may be concerned about various aspects of the six Discussion Drafts released during the third week of December 2014 as part of the Base Erosion and Profit Shifting (BEPS) Action Plan. Three of the papers are within Action items 8 to 10 of the BEPS Action Plan… – Continue reading
As the Organisation for Economic Co-operation and Development (OECD) passes the halfway point in its joint project with the G20 to address base erosion and profit shifting (BEPS) concerns, it is worth pausing to examine what the consequences of some of the proposed changes may be. Much of the focus… – Continue reading
The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing. The link below is to a video summary of the predicted consequences of… – Continue reading
Multinationals told to be more cautious about intra-group transactions as Beijing imposes stiff measures against avoidance and evasion Multinationals have been advised to take notice of Beijing’s New Year resolution to crack down on tax avoidance and evasion, especially after the announcement of the general anti-avoidance rule (GAAR) and new… – Continue reading
IN A PREVIOUS column (http://www.bworldonline.com/content.php?section=Economy&title=the-oecd-action-plan-on-base-erosion-and-profit-shifting&id=99561), we wrote about the general framework of the Base Erosion and Profit Shifting (BEPS) initiative, why addressing BEPS is a key priority for many governments across the globe, and the 15-point BEPS Action Plan drafted by the Organization for Economic Co-operation and Development (OECD). The… – Continue reading
The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then hastingly signed by President Putin in the time span of a week and a half, comes into force on January 1, 2015. The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then… – Continue reading
Businesses in the island’s vital financial services are gearing up for ‘substantial changes’ dealing with tax. That was one of the important messages to come out of a seminar organised by KPMG in the island. More than 200 experts attended the event which covered a series of changes in property… – Continue reading
The conditions for becoming tax-resident and tax non-resident vary from country to country and depend on such things as length of stay, type of accommodation, location of family, and nationality. In most tax systems, presence of an individual in a country for 183 days or more in any 12-month period… – Continue reading
Currently, there is a tendency among those who take an interest in international tax developments to look to the future and try to guess how the international tax landscape will look in, say, three of four years, once countries begin to implement the OECD’s base erosion and profit shifting (BEPS)… – Continue reading
Interview: Outgoing Revenue Commissioners head is proud of her time leading the department The international tax environment is still too unsettled for one to predict how any changes taking place will affect the State’s attractiveness for foreign direct investment, according to outgoing chairwoman of the Revenue Commissioners Josephine Feehily. Feehily… – Continue reading
The OECD is urging governments to tackle interest payments made by multinationals and their subsidiaries as part of a global crackdown on profit shifting. The aim is to also stop companies artificially loading debt in no-tax or low-tax jurisdictions to reduce their tax bills. It comes as the government backs… – Continue reading
Two Australian mining companies will be forced to disclose how much tax they pay in every country around the world by new transparency laws introduced in Canada. Paladin Energy and OceanaGold, both dual-listed in Australia and Canada, will have to comply with new Canadian laws requiring all oil, gas and… – Continue reading
KPMG has responded to the ATO’s recent taxation ruling TR 2014/8 (documentation requirements) and practice statements PSLA 2014/2 (penalties) and PSLA 2014/3 (simplification). Anthony Seve, KPMG transfer pricing partner, said the ruling places increased compliance and documentation obligations on larger companies. This, he said, is reflective of global developments. “Although… – Continue reading
For centuries the inner workings of the Vatican Bank have been cloaked in secrecy. That was before Pope Francis, who has pledged to restore public confidence in the administration of the Roman Catholic Church. This week we learned the United States and the Holy See have brokered a FATCA agreement… – Continue reading
While the Foreign Account Tax Compliance Act (FATCA) has focused worldwide attention on U.S. efforts to create a mandatory cross-border exchange of tax information, the enactment of FATCA was not an isolated occurrence. For more than a decade, the Organisation for Economic Co-operation and Development (OECD) has been trying to… – Continue reading
*Ernst & Young LLP, New York, NY The BEPS beat plays on. Congratulations to the OECD for meeting (mostly) the ambitious goals for release of their reports on seven action items in September 2014 – right on schedule on September 16. The documents released on September 16 relate to Action… – Continue reading
NEW DELHI: The finance ministry is planning to rush through a Cabinet note seeking permission to sign an accord with the US on exchanging investment information before a December 31 deadline, ahead of President Barack Obama’s visit to Delhi at the end of January. The government has got the goahead… – Continue reading
More countries are requiring an exchange of client information In 2014, we saw a marked increase in transparency regarding foreign assets. The United States took the lead, and other countries followed suit. It looks like we’ve reached the tipping point, that is, “the magic moment when an idea, trend, or… – Continue reading
Tax deductions for interest payments could be restricted on a group wide basis, by reference to a fixed ratio, or by a combination of these two solutions, in order to counteract international tax avoidance the Organisation for Economic Co-operation and Development (OECD) has suggested. 19 Dec 2014 Tax Corporate tax… – Continue reading
A discussion document on making dispute resolution mechanisms in international tax disputes more effective is does not provide enough answers to the questions it raises, an expert has said.19 Dec 2014 Tax Disputes and Investigations Tax Corporate tax International tax Europe Asia Pacific Middle East Africa It is “a disappointing… – Continue reading
Bravura Solutions reflects on a year of reform and looks forward to 2015. The Chancellor’s Autumn Statement last week didn’t deliver anything as revolutionary as the reforms announced in his March budget, but there were a few early Christmas crackers around ISA rules. After a monumental year, let’s look at… – Continue reading
Thomas Piketty’s “Capital in the 21st Century” was a 2014 must-read for anyone interested in economics. But while his claim that income and wealth inequality has risen over recent decades to highs last seen before the start of the First World War was widely accepted, his policy prescriptions were not…. – Continue reading
The amendments to the Tax Code of Ukraine, proposed in the draft law on improving tax control on transfer pricing, bring the Tax Code in line with the requirements of the Organisation for Economic Co-operation and Development (OECD) on transfer pricing for multinational companies and tax services. According to a… – Continue reading
