Category: OECD

China ‘to step up supervision of multi-nationals to combat tax avoidance’

Chinese tax authorities have pledged to increase supervision of multi-national companies in a campaign to crack down on tax avoidance.04 Dec 2014 Tax China Asia Pacific Chinese tax authorities have pledged to increase supervision of multi-national companies in a campaign to crack down on tax avoidance. The deputy director of… – Continue reading

Tory veteran David Davis attacks government tax avoidance crackdown as threat to the rule of law

The government has become the biggest threat to the rule of law, according to veteran Tory backbencher and former minister David Davis. Speaking at a briefing organised by the Taxpayers’ Alliance and the Institute of Economic Affairs (IEA) he slammed the government’s attempts to limit tax avoidance through laws such… – Continue reading

Govt guidelines to clarify ‘arm’s length’, ‘ordinary course of business’ definitions

To minimise confusion and litigation, the government will bring fresh guidelines to clearly explain the meaning of terms “arm’s length basis” and “ordinary course of business”, used in the Companies Act, 2013. “After understanding the significance of these two terms for our industry, we have decided to bring fresh guidelines,”… – Continue reading

Global tax war looming and US won’t be backing down

The United States won’t give up its right to tax multinationals, and nations will go to war soon with countries like China on taxing rights, a US tax head says. Grant Thornton’s national managing partner of tax in the United States, Randy Robason, is in Australia this week for a… – Continue reading

UK: Taxation Of Multinationals – UK Government Announcements Related To The G20/OECD Base Erosion and Profit Shifting Initiative

The Chancellor reaffirmed the Government’s continued support for the OECD’s work on base erosion and profit shifting (BEPS) and modernisation of the international framework for taxing multinational companies. Measures in relation to three specific areas are announced – a consultation on hybrid mismatches and the introduction of the OECD’s proposals… – Continue reading

New ‘diverted profits tax’ for multinationals could harm UK businesses, expert says

UK government plans to counter aggressive tax planning techniques used by multinational enterprises to divert profits from the UK to low tax jurisdictions could harm the international prospects of UK businesses according to an expert.03 Dec 2014 Corporate tax Tax Advanced Manufacturing & Technology Services UK Europe The new ‘diverted… – Continue reading

Noonan Discusses Ireland’s International Tax Strategy

Finance Minister Michael Noonan has said that Ireland’s tax regime is fully transparent and that the Government supports international tax reform efforts. Noonan told an Institute of International and European Affairs conference that the world of international taxation is changing rapidly. He pointed out that, “in an increasingly globalized world,… – Continue reading

Autumn Statement 2014: UK plans to raise £1bn with ‘Google tax’

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. The UK announced plans to raise over £1bn over the next five years from a new “diverted profits”… – Continue reading

Corporate tax rate not under threat, says Noonan

The controversial ‘double Irish’ tax mechanism was never part of the Irish tax code and was not a viable way of building a sustainable economy, says Minister for Finance Michael Noonan. Speaking at a major tax conference organised by the Institute of International and European Affairs, Mr Noonan, said the… – Continue reading

Brazil: Brazil Reduces The Income Tax Rate Required From Tax Haven Jurisdictions

The Brazilian Federal Government decided to reduce from 20% to 17% the percentage of the maximum income tax rate required from the low-tax countries classified as “favored taxation country or dependency” (país ou dependência com tributação favorecida) or “privileged fiscal regime” (regime fiscal privilegiado). This measure was adopted by means… – Continue reading

United Kingdom – Hybrid mismatch arrangements consultation, other BEPS-related focus

December 3:  The UK government today issued items that focus on multinational corporations and follow the OECD’s base erosion and profit shifting (BEPS) action plan—one issuance being a consultation document concerning hybrid mismatch arrangements, and the other being the Autumn Statement 2014 that includes provisions relating to country-by-country reporting, the… – Continue reading

UK: Deloitte Preview of Autumn Statement 2014

Bill Dodwell comments: “Chancellor George Osborne will deliver the final Autumn Statement of this parliament. We expect that most of the announcements will concentrate on the outcomes from proposals launched at earlier Budgets, together with some technical changes. There will also be the first consultation on how the UK should… – Continue reading

German complaints could result in higher tax bills

Y​ORKSHIRE​ businesses that invest in research and development could ​face higher tax bills if Chancellor George Osborne uses his Autumn Statement to water down tax breaks following complaints by Germany. One of ​Mr Osborne’s flagship policies is set to be reformed ​on Wednesday following the resolution of a dispute with… – Continue reading

British Virgin Islands: Record Keeping Obligations For BVI Companies, Partnerships, Trusts And Other Organisations

BVI Business Companies A1. What is the law on keeping and retaining records? Section 98 of the BVI Business Companies Act 2004 (BCA) has always provided that a BVI business company must keep records that: are sufficient to show and explain the company’s transactions; and will, at any time, enable… – Continue reading

Cayman Islands: Cayman Islands Financial Account Reporting For Investment Funds

The Cayman Islands currently has in place an intergovernmental agreement (IGA) with each of the United States and the United Kingdom and has passed domestic legislation to make compliance with the IGAs a matter of Cayman Islands law (Cayman FATCA). The Cayman Islands Tax Information Authority (TIA) issued Guidance Notes… – Continue reading

Canada: The BEPS Deliverables: A Macro Critique

What unites the dates February 12, 2013, July 19, 2013, and September 16, 2014? They are the key dates to this point in the OECD’s crusade against base erosion and profit shifting, which will be remembered either as a well-coordinated campaign against abusive tax avoidance by large multinational enterprises, or… – Continue reading

Norway – Proposals for tax reform; maritime industry considerations

December 2:  A tax commission charged with examining the tax system in Norway today submitted its report—NOU 2014: 13—to the Minister of Finance that describes proposals for changes to the corporate tax system and for adjustments to the tax system, in general. The tax commission’s report will be submitted for… – Continue reading

Norway – Proposals for tax reform; maritime industry considerations

December 2:  A tax commission charged with examining the tax system in Norway today submitted its report—NOU 2014: 13—to the Minister of Finance that describes proposals for changes to the corporate tax system and for adjustments to the tax system, in general. The tax commission’s report will be submitted for… – Continue reading

Noonan says OECD tax reforms must be fair to small countries

Project cannot be a ‘dialogue of the privileged’, stresses Minister for Finance Plans to reform the global tax system must not be used to create advantages for larger countries, Minister for Finance Michael Noonan has said. Addressing a conference in Dublin, he said Ireland overwhelmingly supported the Organisation for Economic… – Continue reading

UK: FATCA Compliance And Data Protection

Complying with USA FATCA and UK/EU Data Protection Requirements The US Foreign Account Tax Compliance Act (FATCA), passed by Congress in March 2010, was finally implemented in July 2014. The Act makes the US the only large economy to tax its nationals on all of their earnings anywhere in the… – Continue reading

Ireland needs to ensure developing countries also benefit under international tax changes

The Department of Finance is actively involved in the BEPS process, but how it manages to balance national interests with a commitment to help developing countries reap the benefits of the reforms remains to be seen’ The recent Luxembourg leaks have kept the spotlight firmly on the lengths to which… – Continue reading

German complaints could result in higher tax bills

Y​ORKSHIRE​ businesses that invest in research and development could ​face higher tax bills if Chancellor George Osborne uses his Autumn Statement to water down tax breaks following complaints by Germany. One of ​Mr Osborne’s flagship policies is set to be reformed ​on Wednesday following the resolution of a dispute with… – Continue reading

Taxation of Esops when on a foreign assignment

Stock award is a popular method of rewarding talented and industrious employees. However, employees who render services across different jurisdictions may trigger a taxable presence in two or more jurisdictions. Such employees at times need to deal with the issue of double taxation on such benefits. A normal stock incentive… – Continue reading

FTSE 350 prefer Ireland to UK as top tax regime

Ireland has knocked the UK off the top spot as the most competitive tax destination, according to KPMG’s annual survey of Britain’s largest businesses However, the UK has increased the number of times it is mentioned in the companies’ top three competitive tax regimes. The KPMG Annual Survey of Tax… – Continue reading

George Osborne’s targeting of corporate tax dodges faces voter scepticism

George Osborne’s targeting of corporate tax dodges faces voter scepticism • Chancellor waters down tech company measures • Disbelief will greet key plan in autumn statement Almost 60% of adults in the UK don’t believe politicians’ promises to tackle corporate tax avoidance, according to a damning poll published ahead of… – Continue reading

FATCA ticks on

It feels like FATCA has been around for years already, yet some companies are still coming to terms with its implications. However, as Kirsten Morel explains, impending deadlines are now creating a real sense of urgency It’s four years since US Congress enacted the Foreign Account Tax Compliance Act (FATCA),… – Continue reading

Tax and investment protection trends in Africa in 2014 and predictions for 2015

In the African tax sphere, the trend remains for headline tax rates to continue to remain stable or decrease. Withholding tax rates have generally remained stable, although the experience of Dentons and our clients is that African tax authorities are requiring tax to be withheld from payments that have not… – Continue reading

New Zealand – Inland Revenue’s timeline for BEPS consultations

December 1:  The Inland Revenue last week released its annual compliance guide for taxpayers and reports on progress with respect to the OECD’s base erosion and profit shifting (BEPS) work and time frames, for New Zealand consultation on possible domestic law changes to address BEPS concerns. The 2014/15 compliance guide… – Continue reading

Luxembourg: a tax haven by any other name? Professor on ‘secret’ tax deals

The revelations that global and multinational businesses have been brokering “secret” tax deals with Luxembourg to avoid paying taxes in their home countries, may be the first time an entire country has been implicated in tax avoidance collusion. A cache of leaked agreements uncovered by the International Consortium of Investigative… – Continue reading

G20 gives Africa the will to deal with tax evasion

To prevent cross-border tax evasion, we endorse the global Common Reporting Standard for the automatic exchange of tax information (AEOI) on a reciprocal basis. We will begin to exchange information automatically with each other and with other countries by 2017 or end-2018, subject to completing the necessary legislative procedures,’’ says… – Continue reading

Out of 627, 427 black money account holders identified: Arun Jaitley

With the Opposition targeting the government on the black money issue, Finance Minister Arun Jaitley told the Rajya Sabha on Wednesday that the identity of 427 foreign account holders has been established, of which 250 have admitted to having these accounts. Replying to a debate on the issue, Jaitley said… – Continue reading

Accountants cheer the UK and the Netherlands for simple tax rules

European tax experts say that despite rule changes, Britain has one of the clearest systems Tax professionals view the Netherlands and the UK as the most attractive European countries in which to do business, according to a new survey. The two countries scored well on how simple their tax rules… – Continue reading

Guernsey issues bulletin to update draft guidance notes on FATCA-based reporting

On 21 November, the States of Guernsey Income Tax (ITO) published bulletin 2014/1 to update the most recent iteration of the draft guidance notes issued jointly by the crown dependencies on 28 July 2014 regarding the implementation under domestic law of FATCA-based reporting. The bulletin provides clarification in response to… – Continue reading

Dodwell: BEPS reform is forcing Ireland to reform tax rules

The latest work by the OECD tax policy team to review global tax rules is beginning to have an impact, particularly in Europe where Switzerland and Ireland are reforming their current tax rules, says Bill Dodwell, head of tax policy at Deloitte One unsurprising outcome of the OECD’s Base Erosion… – Continue reading

Netherlands responses to interim reports on BEPS project

Introduction On 19 September the Dutch State Secretary for Finance Mr Wiebes responded to the release of the 2014 interim reports on the OECD BEPS project. The Netherlands underlines the importance of the initial results of the BEPS project and is one of the forerunners in the international cooperation against… – Continue reading

Progress reports released on tax avoidance

Progress reports released on tax avoidance Revenue Minister Todd McClay today released two reports from officials relating to tax avoidance by large multinational companies. The reports provide an update on policy work being undertaken in line with the OECD Action Plan and also outline the expected timeline for related policy… – Continue reading

Panama is not a tax haven

Mr. Eduardo Morgan of Morgan and Morgan Group spoke to United World to clear up misconceptions about Panama’s tax laws. Panama is not a tax haven. The country has none of the aspects that, according to Colombia, identify a tax haven. Our tax legislation does not have any law that… – Continue reading

ATO letting big multinationals get away with it

Martin Lock was formerly the top withholding-tax specialist at the Tax Office, a role that encompassed oversight of profit shifting by multinationals. He is one of many former officers who have voiced their concerns to Fairfax Media about the challenge of arresting the slide in tax receipts from multinational companies… – Continue reading

Barbados Promoted To OECD Global Forum Vice Chair

The Barbados International Business Association (BIBA) has welcomed Barbados’s appointment to Vice Chair of the Global Forum of the Organization for Economic Cooperation and Development (OECD), saying that the decision validates the jurisdiction’s good standing among international business and financial centers. Barbados is to take over from Bermuda, for two… – Continue reading

OECD Considers Availability of Tax Treaty Benefits for Investment Funds, Pension Funds and Private Equity Funds

On November 21, 2014, as part of its Action Plan on Base Erosion and Profit Shifting (BEPS), the OECD released a discussion draft on “Follow-up work on BEPS Action 6: Preventing Treaty Abuse” (the Discussion Draft) for comments. The Discussion Draft deals with a number of issues relating to tax… – Continue reading

OECD draft addresses tax treaty shopping

The OECD has invited comments on a discussion draft on proposed changes to the OECD model tax convention to prevent tax treaty abuse. The OECD’s recent report on action 6 of the base erosion and profit shifting (BEPS) action plan recognised that further work would be needed on the precise… – Continue reading

Transfer Pricing: A Developing Area in Slovak Tax Law

Transfer pricing can be identified as an area of tax law that continues to attract the attention of both tax authorities and businesses worldwide. The growing importance of transfer pricing can be observed in the Slovak Republic as well, as it has become one of the dominant tax issues addressed… – Continue reading

Tougher operating environment calls for a new business model

Rüschlikon is just a 20-minute boat ride from the centre of Zurich, yet a world away from the intense rivalry of the city’s financial powerhouses. Every autumn, the sleepy lakeside settlement hosts the Private Banking Summit, where delegates seek safeguards for their threatened industry. “Swiss private banking is in turmoil,… – Continue reading

Base erosion and profit shifting – a South African perspective

The concept of base erosion and profit shifting (BEPS) has been debated at various international forums following discussions at the G20 Finance Ministers and Central Bank Governors meeting and the G20 Heads of State summit in Russia last year. The Organisation for Economic Co-operation and Development’s (OECD) BEPS Action Plan… – Continue reading

Base erosion and profit shifting – treaty shopping

The concept of base erosion and profit shifting (“BEPS”) has been much discussed at various international forums including the G20 Finance Ministers and Central Bank Governors meeting in July 2013 in Moscow as well as the G20 Heads of State meeting in September 2013. From a South African perspective, the… – Continue reading

Clampdown on tax avoidance

By closing the tax gap, South Africa can reap billions of rands to benefit the economy. A global crackdown on tax avoidance has begun and South Africa is forging ahead in a bid to tackle wealthy individuals and corporates who practise this tactic. The initiative is better poised to succeed… – Continue reading

BEPS – Discussion draft on follow-up work under Action 6 (prevent treaty abuse)

November 21:  The Organisation for Economic Cooperation and Development (OECD) today released a discussion draft [PDF 179 KB] concerning follow-up work as mandated under a report with respect to Action 6 (prevent treaty abuse) under the base erosion and profit shifting (BEPS) action plan. Background The OECD in September 2014… – Continue reading