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
On September 16, 2014, the Organisation for Economic Cooperation and Development (“OECD”) released seven reports addressing certain aspects of the base erosion and profit shifting (“BEPS”) project. The seven BEPS reports released by the OECD include tax challenges of the digital economy (Action 1), hybrid mismatch arrangements (Action 2), countering… – Continue reading
Action 6 of the BEPS Action Plan identified treaty abuse as one of the most important sources of BEPS concern. The report offers alternative model provisions for the prevention of treaty abuse given constitutional and other restrictions that may apply to some treaty countries. Notwithstanding, each alternative shares a common… – Continue reading
Background In July 2013, the G20 Finance Ministers, including Australia, fully endorsed the base erosion and profit shifting (BEPS) Action Plan. As a result of the Action Plan, the Australian government encouraged a new commitment to focus resources on investigating international business structures to ensure companies pay tax in the… – Continue reading
The FATCA Readiness Self-Assessment Survey indicates companies are not as prepared for the new regulation as they should be. As part of an initiative to better understand client requirements in accordance with FATCA regulation, software development company, Blue Bison recently conducted a FATCA Readiness Self-Assessment Survey among financial institutions across… – Continue reading
28 November 2013 ” (George Town, Grand Cayman) The OECD has released the latest ratings against compliance with FATF recommendations rating the Cayman Islands “Largely Compliant”. The rating places the Cayman Islands only one level below the maximum rankings and places the jurisdiction in the same category as countries such… – Continue reading
Meredith McBride in Hong Kong Mitsubishi Corporation India’s victory over the Indian tax authorities in the New Delhi Tax Tribunal on the use of the Berry ratio (gross margin divided by operating expenses) sets important precedents for transfer pricing litigation in India, advisers believe, because it legitimises the use of… – Continue reading
Action Item 5 of the BEPS Action Plan commits the Forum on Harmful Tax Practices (“FHTP”) to: “revamp the work on harmful tax practices with a priority on improving transparency, including compulsory spontaneous exchange on rulings related to preferential regimes, and on requiring substantial activity for any preferential regime. It… – Continue reading
Small- and medium-sized firms are unprepared for tough new US tax reporting legislation, a survey has found. Software firm Blue Bison, part of the Ignition group of companies, found that more than half of respondents to its readiness survey admitted that understanding the requirements of the Foreign Account Tax Compliance… – Continue reading
MPs have attacked the taxman for being too slow to crack down on controversial avoidance schemes used by celebrities and other high earners, resulting in millions of pounds being lost to the public purse. As much as £10 million may never be recoverable because of delays by Her Majesty’s Revenue… – Continue reading
The Finance Bill 2014 (the “Bill”), which was published 23 October 2014, proposes a package of measures which focuses on Ireland’s tax rate, regime and reputation. The changes seek to reinforce Ireland’s position as a top destination for multinational companies and emphasise the importance of real and substantive foreign direct… – Continue reading
Russia’s lower house of parliament on Tuesday took aim at the offshore holdings that have become ubiquitous in Russian business, passing in its final reading a bill that will make Russian taxpayers declare and pay taxes on their assets abroad. But once signed into law, this product of President Vladimir… – Continue reading
There are two ways to approach a G20 summit. One is to seek to provide solutions to major international problems affecting the global economy and get other countries to sign up for them. The other is to go with a largely domestic agenda and tomtom it, but in large part… – Continue reading
The European Commission, in an “Opening Decision” published on November 14, 2014, said that an advance tax ruling provided by the Netherlands to coffee group Starbucks appears to constitute state aid, in violation of European Union (EU) rules. In a 40-page letter to the Dutch authorities, the Commission detailed the… – Continue reading
On 11 November 2014, the UK and Germany made a joint announcement about a proposal they had developed to address some of the concerns raised over the OECD’s suggested approach to dealing with preferential IP tax regimes. These regimes will close to new entrants from June 2016, and will be… – Continue reading
A publication in the Economic Times has caused much debate in India since after blacklisting Cyprus for not sharing information on tax evaders, India is now looking to take away the favourable tax treatment available to investors from the European tax heaven under the bilateral tax treaty between the two… – Continue reading
The G20 Communique is good news on the international tax reform front. As part of the G20 commitment to boost economic resilience the Communique commits G20 nations to taking action to ensure fairness in the international tax system. This means they are looking at ways to ensure profits are taxed… – Continue reading
Oxfam director Winnie Byanyima says what is on the table is not enough to stop poor countries being ‘bled dry’ Moves by G20 nations to tackle corporate tax avoidance are welcome but will only begin to uncover the full problem while leaving poor countries still vulnerable to exploitation, tax justice… – Continue reading
New Zealand is planning to crackdown on tax evaders and combat the menace of avoidance by international firms. As part of the exercise, New Zealand will work with an international action plan being spearheaded by the OECD. This was stated by Finance Minister Mr. Bill English. He told media persons… – Continue reading
Economic growth in France may exceed the Organization for Economic Co-operation and Development’s (OECD) 0.4 percent target this year, finance minister Michel Sapin told CNBC over the weekend. “The last figures for the third-quarter are figures that fill me with trust. This year, France will reach the 0.4 percent [target],… – Continue reading
In today’s global economy, where multinational companies do business in different geographical and tax jurisdictions, the need for arm’s length pricing of related party transactions is a growing concern for revenue authorities. Tax bodies are increasingly requiring multinationals to document their related party transactions. Where these transactions are not well… – Continue reading
The latest G20 leaders’ summit in Australia, which ended yesterday, has endorsed the various strands of international tax work being undertaken by the European Commission and by OECD, including work on the Base Erosion Profit Shifting (BEPS) project Prime Minister David Cameron said there had been ‘important breakthroughs’ in making… – Continue reading
Pretoria — President Jacob Zuma has concluded his visit to Brisbane, Australia, where he led the South African delegation to the G20 Leaders’ Summit, says the Presidency. The main outcome of the Leaders’ Summit was a commitment to lift the G20’s Gross Domestic Product (GDP) by at least an additional… – Continue reading
Fifty-one countries signed the Multilateral Competent Authority Agreement in Berlin on Oct. 29 to fight offshore tax fraud and evasion. The agreement aims to put an end to banking secrecy by sharing tax-related information with member states. Missing from the signatory list are the United States and China. China’s absence… – Continue reading
G20 leaders have made “real progress” towards ensuring that “big companies pay the tax they owe”, David Cameron said at the end of the G20 summit in Brisbane yesterday. “There are now over 92 different countries and tax authorities properly sharing information and, as the OECD set out at this… – Continue reading
Recent months saw various important developments that are relevant to Sino-European trade and investment. These include (i) changes to the EU Parent-Subsidiary Directive, (ii) the entry into force of the double tax treaty between Luxembourg and Taiwan, and (iii) proposed changes to China’s Foreign Investment Catalogue and the Governmental Verifications… – Continue reading
There is broad global support for moves to curb international tax avoidance, says Finance Minister Bill English, on the sidelines of the G20 Leaders’ Summit in Brisbane. Cracking down on tax avoidance is one of the key agenda items at this weekend’s G20 Summit, where New Zealand is an invited… – Continue reading
BRISBANE, Australia — Under pressure to jolt the lethargic world economy back to life, leaders of G-20 nations on Sunday finalized a plan to boost global GDP by more than $2 trillion over five years. The fanfare, however, was overshadowed by tensions between Russian President Vladimir Putin and Western leaders…. – Continue reading
You know those annoying “We Agree” television ads by the fossil fuel corporate giant Chevron? The ones where an actor playing a student or a concerned member of a community “agrees” with supposedly noble objectives of this multinational? Those ads make me feel like puking. The objective of this campaign… – Continue reading
BRISBANE: Australia has vowed a “very aggressive” crackdown on tax avoidance at weekend G-20 talks, as a row rages over Luxembourg’s sweetheart arrangements with multinationals. Closing corporate tax loopholes and endorsing a common reporting standard to increase transparency are set to be a primary focus of the G-20 summit in… – Continue reading
Expats have a range of choices – so how do they find a safe home for their assets? The traditional use of offshore centres as a way of enabling better tax planning – and even tax evasion – has all but fallen away. An increasing desire for countries to share… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) released this week a strategy for deepening developing-country engagement in its work to stop the erosion of national tax bases and the shifting of profits to jurisdictions solely to avoid paying tax. The emerging-market strategy, designed to strengthen developing-country involvement in decision-making… – Continue reading
(AFP) The OECD Friday forecast competition heating up among countries wanting to attract revenue from big digital companies like Apple and Google, even as a row rages over Luxembourg’s arrangements with multinationals. Closing corporate tax loopholes and endorsing a common reporting standard to increase transparency are set to be a… – Continue reading
The OECD’s head of tax has rejected calls to publicly release country-by-country breakdowns of taxes paid by multinationals, despite growing pressure from community and transparency groups. Agencies such as Transparency International and a host of community groups are putting pressure on the OECD and G20 leaders at the summit in… – Continue reading
Hybrid entities have long been a tool for corporate tax planning. While tax authorities have fought the use of such hybrid mismatches for tax planning purposes, national efforts to prevent the use of hybrid mismatches have not proven to be very efficient, explain Michael Graf and Timothy Santoli, of Dentons… – Continue reading
The LuxLeaks scandal is a classical example of the growingly frequent clash between the level of integration of the European economy (and the global for that matter) and the national sovereignty. Greece was first to prove that four years ago when it put to the test the very survival of… – Continue reading
Multinational tax avoidance risks losing citizens’ trust, says Joe Hockey G20 working on ‘important reforms which will significantly improve the integrity of the tax system’, Australian treasurer says The Australian treasurer, Joe Hockey, has warned that citizens will lose trust in the legitimacy of their governments if multinationals are allowed… – Continue reading
The Swiss Federal Council has adopted dispatches on five double taxation agreements, which will now be submitted to Parliament for approval. The treaties with Estonia, Ghana, Iceland, and Uzbekistan either replace or revise the current deals, while the agreement with Cyprus is Switzerland’s first with the territory. All of the… – Continue reading
Y20 head on youth unemployment mission Countries may have to battle for revenue from digital companies once the global plan to stop tax avoidance succeeds, says the OECD’s head of tax Pascal Saint-Amans, but at least they now have something to fight for. In an exclusive interview with Fairfax Media… – Continue reading
(Reuters) – A showdown between Western leaders and Russian President Vladimir Putin is likely at the G20 summit in Australia starting on Saturday, following fresh reports of Russian troops pouring into eastern Ukraine. Ukraine has accused Russia of sending soldiers and weapons to help separatist rebels in eastern Ukraine launch… – Continue reading
Brisbane (Australia) (AFP) – The Organisation for Economic Co-operation and Development on Friday forecast competition heating up among countries wanting to attract revenue from big digital companies like Apple and Google, even as a row rages over Luxembourg’s arrangements with multinationals. Closing corporate tax loopholes and endorsing a common reporting… – Continue reading
NEIL CHENOWETH Global accounting firm PwC was advising the Australian Taxation Office how to run its transfer pricing unit at the same time that its Luxembourg office was cutting favourable tax agreements for Australian companies. Luxembourg documents show PwC obtained secret tax agreements for more than 30 Australian companies in… – Continue reading
Indian economy is expected to see an average growth of 6.7 per cent over the 2015-19 period and a further boost would depend on reform plans of the government, says a report. However, the Organisation for Economic Cooperation and Development (OECD) on Thursday also said India and China face significant… – Continue reading
THE WORLDWIDE increase in digital commerce has alerted many countries to the unique tax challenges it presents. Facing up to tax challenges in the age of digital economy THE WORLDWIDE increase in digital commerce has alerted many countries to the unique tax challenges it presents. There is now a common… – Continue reading
Prime Minister Tony Abbott has nominated global tax avoidance as one of the key issues on the agenda for this weekend’s G20 summit in Brisbane. Major companies including Google and Apple have faced strong criticism over their efforts to lower their tax bills by shifting profits to jurisdictions with low… – Continue reading
In what should come as a boost for the new Narendra Modi government, the Organisation for Economic Cooperation and Development (OECD) says India is the “only major economy” that is projected to see a pick-up in growth momentum. The Paris-based think-tank saw mixed trends for the developed world, according to… – Continue reading
The OECD released today its new Strategy for Deepening Developing Country Engagement in the Base Erosion and Profit Shifting (BEPS) Project, which will strengthen their involvement in the decision-making processes and bring them to the heart of the technical work. The BEPS Project aims to create a coherent set of… – Continue reading
New Delhi: Absence of criminal legal treaties between India and tax haven nations have been cited by probe agencies working in the SIT on black money as one of the major impediments in initiating steps to bring back illegal funds stashed abroad by Indians. These agencies, including the Central Board… – Continue reading
INSTITUTIONAL investors from three countries that are G20 members have called on this week’s summit to ensure transparency and disclosure are part of the G20’s talks on tax avoidance. The investors, including multi-billion dollar companies from the United Kingdom, Canada and France, and non-G20 nation The Netherlands, made the call… – Continue reading
India will soon put its signature on an agreement for exchange of information to curb tax evasion after refusing to sign the multilateral pact along with 51 nations in Berlin last month. Finance Ministry officials told Deccan Herald that the government was currently in the process of completing the internal… – Continue reading
