This is going to be the plum job for any international tax practitioner: Competent Authority for the Republic of Ireland. It seems pretty clear that the Base Erosion and Profit Shifting (BEPS) project will meet its announced deadline of the end of 2015 to produce final reports on all of… – Continue reading
There has been a recent surge in anti-tax inversion legislation discouraging companies attempting to shift corporate subsidiaries or headquarters to low-tax or tax-free countries. The issue was subjected to a great deal of publicity in April 2014 during the failed hostile takeover by Pfizer (NYSE:PFE) for AstraZeneca (NYSE:AZN) when Pfizer… – Continue reading
The Cayman Islands Tax Information Authority (“Cayman TIA”) issued the second official version of the Cayman Islands FATCA Guidance Notes (the “Guidance Notes”) on 15 December 2014. A copy of the Industry Advisory and the Guidance Notes can be found through the following links: Industry Advisory Guidance Notes on the… – Continue reading
India will start charging income tax on digital economy firms, such as Facebook, Twitter and Uber, soon after the OECD finalises a framework by April 2015 to tackle the widespread corporate practice of shifting of profits to low-tax countries, government officials said on Wednesday. Tax may be levied on overseas… – Continue reading
Where do things stand with the government’s efforts to combat corporate tax avoidance and evasion, one of its priorities as G20 chair in 2014? The headlines suggest a contradictory stance. The latest headline is that Treasurer Hockey ‘backflips on tax laws to target multinational profit-shifters’. This refers to the announcement… – Continue reading
The OECD (Organisation for Economic Co-operation and Development), in its latest economic survey of Australia, recommends a change to the tax mix including increasing the GST (Goods And Services Tax) by 50% or more. “Make greater use of efficient tax bases such as the Goods and Services Tax and land… – Continue reading
The United States Council for International Business (USCIB) has warned that the United Kingdom’s proposal to impose a new tax on so-called “diverted profits” (DPT) would, if implemented, have a major impact on US-based multinational companies. The rules, contained in UK Government’s recent Autumn Statement, propose a 25 percent DPT… – 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
Think tank targets key aspects of Republic’s role in multinationals’ tax affairs Key features of Ireland’s role in the tax affairs of major technology companies such as Google and Microsoft are being targeted by the OECD’s base-erosion and profit-shifting (Beps) project, it has emerged. Ideas being worked on by the… – Continue reading
Unlike China, Japan‘s manufacturing activities rose in December. Flash PMI from HSBC came out at 52.1, up from 52 in November. A reading over 50 signals expansion. Meanwhile, the Nikkei newspaper reported that Japan’s government is considering lowering the corporate tax rate by 2.5 percentage points starting next April. Among… – Continue reading
Defending the interests of the Swiss banking industry has not been the easiest challenge in recent years, particularly when it comes to tax. The role has fallen for the last five years to Patrick Odier, chairman of the Swiss Bankers’ Association (SBA), which has 317 institutional members and about 18,500… – Continue reading
December 16: The Organisation for Economic Cooperation and Development (OECD) today released two discussion drafts under the base erosion and profit shifting (BEPS) project that focus on transfer pricing aspects—specifically under BEPS Action 10 (“Assure that transfer pricing outcomes are in line with value creation” in relation to “other high… – Continue reading
While the media has been feasting on Lux Leaks and other stories of “multinational tax dodging”, academic accountants have determined that U.S. multinational corporations (MNCs) have no particular tax advantage over U.S. domestic firms. In fact, a new study finds the average effective tax rate for U.S. MNCs is slightly… – Continue reading
A new standard that would help stamp out tax evasion by forcing multinationals to give governments details about their tax affairs has been uncosted by Treasury, the latest budget update shows. Under a plan agreed to at the G20 finance ministers meeting in Cairns held earlier this year and then… – Continue reading
A collection of valid points of view 1.The Island Editorial says 2. Further Analysis by Nalliah Thayabharan 3 More observations by Christie 4. Some more observations by Nimal 5. A Possible Solution by NeelaMahaYoda The Island Editorial says; “Opposition presidential candidate Maithripala Sirisena claims that the government leaders’ corrupt deals… – Continue reading
Law360, New York (December 15, 2014, 5:52 PM ET) — Coming guidance from the Organization for Economic Cooperation and Development’s base erosion and profit shifting project on the implementation of the country-by-country reporting of financial information for transfer-pricing purposes will seek to make those reports as broadly accessible to governments… – Continue reading
The government’s plans to implement a Diverted Profits Tax (DPT) have been questioned by the Association of Chartered Certified Accountants (ACCA). Chas Roy-Chowdhury, head of taxation at the body, said nobody wants profits that should be subject to UK tax “escape the net”. As a result, he believes it is… – Continue reading
Background On 15 December, 2014, the OECD hosted a webcast to update the global tax community on progress under the Base Erosion and Profit Shifting (“BEPS”) Plan. This year, the OECD produced 10 different reports (“BEPS Reports”) covering several actions specific to transfer pricing. This latest OECD webcast summarised efforts… – Continue reading
Some of the best tax minds in the country agree on one thing: Corporate tax reform will be a very, very heavy lift. Sure, the White House and top lawmakers who will be in charge of writing tax law next year have signaled their openness to the idea. And, yes,… – Continue reading
Illicit Flows from Developing & Emerging Countries Growing at 9.4% per Year US$6.6 Trillion Stolen from Developing World from 2003-2012; Trade Misinvoicing Responsible for 77.8% of Illicit Outflows China, Russia, Mexico, India, Malaysia—in Declining Order—Are Biggest Exporters of Illicit Capital over Decade; Sub-Saharan Africa Still Suffers Biggest Illicit Outflows as… – Continue reading
JAKARTA, Dec 15 — Indonesia and Singapore have agreed to step up efforts to share tax-related information to tighten loopholes on tax evasion in each other’s countries, Indonesia’s finance ministry said. The commitment came after Indonesia’ Finance Minister met his counterpart Tharman Shanmugaratnam in Singapore today, the ministry said in… – Continue reading
IN TAX, the latest global buzzword is “BEPS” or base erosion and profit shifting. BEPS refers to the practice of multinational corporations (MNCs) of shifting profits from high tax jurisdictions to low tax jurisdictions as a tax mitigation strategy. In February 2013, the Organization for Economic Co-operation and Development (OECD)… – Continue reading
As multinationals are forced to reveal more about themselves, where should the limits of transparency lie? HOWARD SCHULTZ, the head of Starbucks, said last year that “the currency of leadership is transparency.” If so, bosses should be feeling ever more qualified to command their troops. Business is being forced to… – Continue reading
There’s big news from across the pond. The U.K. government’s Autumn Statement (formerly known as the pre-Budget report), released December 3, promises to change how multinational corporations will be taxed – and offers a cautionary tale for would-be U.S. tax reformers. Britain will introduce a “diverted profits” tax, targeting corporations… – Continue reading
This is a United World interview for USA Today for a report on Antigua and Barbuda. Brian Stuart-Young, CEO of Global Bank of Commerce and Non-resident Ambassador to China, spoke about opportunities for American investors in the energy sector, Antigua’s robust framework for financial services, and the potential for the… – Continue reading
There’s big news from across the pond. The U.K. government’s Autumn Statement (formerly known as the pre-Budget report), released December 3, promises to change how multinational corporations will be taxed – and offers a cautionary tale for would-be U.S. tax reformers. Britain will introduce a “diverted profits” tax, targeting corporations… – Continue reading
This Alert provides more details on the most significant measures contained in the draft Finance Bill. Draft clauses of the UK Finance Bill 2015 were published on 10 December 2014. They will now be the subject of consultation until 4 February 2015. This Alert provides more details on the most… – Continue reading
Do trustees need to register with the US Internal Revenue Service (the “IRS”) before 1 January 2015? Does registration need to be made in respect of a trust? These questions need to be given due consideration by Cayman Islands and British Virgin Islands (“BVI”) trustees and the trusts in respect… – Continue reading
THE CONCLUSION of an air services agreement and training opportunities for Barbadians were among the areas discussed, when India’s High Commissioner, Subashini Murugesan, paid a courtesy call on Permanent Secretary in the Ministry of Foreign Affairs, Charles Burnett. Burnett received the High Commissioner on behalf of the Minister of Foreign… – Continue reading
Maples and Calder Michael Gagie, Richard Grasby, Tim Clipstone, Christopher Capewell, Jon Fowler and Tim Frawley Do trustees need to register with the US Internal Revenue Service (the “IRS”) before 1 January 2015? Does registration need to be made in respect of a trust? These questions need to be given… – Continue reading
A new UK tax on the ‘diverted profits’ of multinationals operating in the UK “is probably not needed, will be hard to apply and will raise little money” according to one expert. 10 Dec 2014 Corporate tax Tax International tax UK Europe Heather Self of Pinsent Masons, the law firm… – Continue reading
Minister of state stresses taxation rates remains a matter for member states Ireland has “nothing to fear” from European proposals to tackle multinational tax avoidance, the Minister of State at the Department of Finance Simon Harris said on Tuesday as EU finance ministers rubber-stamped new rules on the automatic exchange… – Continue reading
This publication provides a brief overview of the expected impact on entities established in Bermuda of (a) the foreign account tax compliance provisions (“FATCA”) of the Hiring Incentives to Restore Employment Act, 2010 of the United States of America (the “US”); and (b) equivalent rules implemented in relation to United… – Continue reading
Australia’s GST rate is now half the average of the developed world, according to the Organisation for Economic Co-operation and Development, building the case for the issue to be looked at as part of the federal government’s upcoming tax review. In an interview with Fairfax Media the OECD’s head of… – Continue reading
Australia may follow the UK in implementing a “diverted profits” tax on multinationals to crack down on tax avoidance. Joe Hockey, Australia’s treasurer, said on Tuesday that his office is exchanging information with London on its “Google tax”, which was announced last week, writes Jamie Smyth in Sydney. I am… – Continue reading
In the past fifty years, European nations have become increasingly reliant on value-added taxes, according to a recent study released in December by the Tax Foundation. The study, authored by Tax Foundation Center for Federal Tax Policy economist Kyle Pomerleau, details the rising popularity in Europe of the value-added tax… – Continue reading
The Swedish Tax Agency has, on request by the Swedish Government (Ministry of Finance), evaluated the transfer pricing documentation rules’ functionality and proposed possible changes to simplify the application. The first step was to make an international comparison of the rules in relevant, comparable OECD countries. An overall assessment showed… – Continue reading
Thousands of rich Australians have come forward to declare billions of dollars in untaxed assets and income stashed in bank accounts in Switzerland and in other countries. The rush comes as what the Australian Taxation office says is the last tax amnesty it will ever offer comes to an end…. – Continue reading
The MT Conferences section did not involve the reporting or the editorial staff of The Moscow Times. Russian business is trembling in expectation of the new year when major changes recently introduced to the tax legislation will enter into force. There has been a lot of discussion regarding the increase… – Continue reading
As India continues its pursuit of black money allegedly stashed abroad, Switzer-land has said it would not entertain any ‘fishing expedition’ and authorities cannot ask for names of all Indian account holders in Swiss banks without doing their own independent investigations. Switzerland’s Ambassador to India Linus von Castelmur also said… – Continue reading
Global regulators need to standardise the mechanisms by which financial institutions exchange tax information on their clients amid concern the number of tax information exchange agreements between various countries is spiraling out of control. This comes as a number of countries and global regulatory bodies introduce their own tax reporting… – Continue reading
President Luis Guillermo Solís said that Costa Rica would present its application to join the Organisation for Economic Co-operation and Development in June 2015, during remarks following a meeting with the organization’s president in Mexico on Sunday. The meeting with OECD President José Ángel Gurría took place during a business… – Continue reading
The luxleaks scandal has been used as “cover” by big European nations to point the finger at the tax affairs of small countries like Ireland and try to push through rules that suit their own interests, according to Fine Gael’s Brian Hayes. The MEP, who sits on the parliament’s economic… – Continue reading
The exchange of information between tax authorities worldwide is about to enter into a new phase of an active gathering and reporting of data. The eradication of tax evasion has now been elevated to a matter of priority amongst OECD states. There has been an unprecedented push to expand the… – Continue reading
The Tax Commission, appointed by the Government in March last year to review corporate taxation in Norway in light of international developments, submitted its report on December 2, and proposed a cut in both corporate and individual income tax rates, alongside other adjustments to combat corporate base erosion and profit… – Continue reading
Brisbane communiqué, after the G20 heads of government summit, and that from their finance ministers, after their earlier meeting in Cairns, along with recent developments in the Forum on Tax Administration mean for business. The Brisbane communiqué contained one paragraph on tax. It read: 13. We are taking actions to… – Continue reading
Brisbane communiqué, after the G20 heads of government summit, and that from their finance ministers, after their earlier meeting in Cairns, along with recent developments in the Forum on Tax Administration mean for business. The Brisbane communiqué contained one paragraph on tax. It read: 13. We are taking actions to… – Continue reading
The US and Canada are at the forefront of a global increase in new mutual agreement procedures (MAPs) being initiated, OECD figures show. There were 1,910 new MAPs in 2013, a 14% increase from 2012, when there were 1,678 new MAPs. North America accounted for most of this growth, with… – Continue reading
Two things should be said about the UK’s new Google GOOGL -2.7% Tax as proposed in the Autumn Statement by George Osborne, the Chancellor of the Exchequer. The first is that there really is a certain amount of public anger about the manner in which the big tech companies (here… – Continue reading
Forward thinking is part of the Luxembourger mentality. As the country prepares to bring its tax rules in line with the rest of the EU, it’s aiming to become a hub for storing and trading art and other high-end collectibles Luxembourg refuses to stand still. Obsessed with diversifying its economy,… – Continue reading
