Category: OECD

Noonan Asserts Ireland’s Direction On Tax Policy

“The issue of substance and taxation is, and always will be, a core column of the Irish taxation system,” Michael Noonan, Ireland’s Finance Minister, said at his Department’s Tax Policy Conference on October 21, 2014, underscoring that Ireland’s strategy is to play fair but play to win. Beginning by discussing… – Continue reading

‘Ireland Inc’ summit: US-Irish business mergers ‘are not about avoiding tax’ says ambassador

Countries that work together like Ireland and the US “need to be cognisant” of the impact their tax policies have on each other, new US Ambassador to Ireland Kevin O’Malley said in a speech yesterday. He said cross-border mergers can make the Irish and American economies stronger, but that “these… – Continue reading

Statement of the OECD Working Group on Bribery on France’s implementation of the Anti-Bribery Convention

23/10/14 – After a comprehensive review in October 2012, the OECD Working Group on Bribery asked France, through a series of concrete recommendations, to intensify its actions to fight the bribery of foreign public officials and undertake important reforms. In October 2014, the Working Group welcomed several significant reforms, including:… – Continue reading

Australians confess to stashing $1b in assets offshore

Around $180 million in undeclared offshore income has now been recovered as part of the amnesty, the ATO said. A further $1 billion in assets has also been recovered. Photo: Louie Douvis The Tax Office is keeping a close eye on foreign banks as part of its push to stop… – Continue reading

Business-Friendly Bureaucrat Helped Build Tax Haven

LUXEMBOURG — On the first floor of a rust-colored building near the main railway station, Marius Kohl spent years engineering this country’s most valuable export: tax relief. As head of a federal agency called Societes 6, Mr. Kohl approved thousands of tax arrangements for multinational corporations, sometimes helping them save… – Continue reading

OECD gives cautious welcome to Knowledge Box tax scheme

THE OECD has signalled support for the Government’s plan to introduce a so-called “Knowledge Development Box”, but warned that the devil would be in the detail. Pascal Saint-Amans, the director of the Centre for Tax Policy and Administration at the Paris-based Organisation for Economic Cooperation and Development (OECD), told the… – Continue reading

OECD Enters French Tax Reform Debate

The Organisation for Economic Cooperation and Development (OECD) has recommended a number of direct tax reforms to build on the French Government’s efforts to improve the nation’s competitiveness in Europe. The report points out that the tax wedge (the cumulative burden of taxes on workers) in France is among the… – Continue reading

Swiss process on for amending tax pacts to comply with global norms

BERN/NEW DELHI: To comply with global norms, Switzerland today began consultation process for unilaterally amending bilateral tax treaties to allow exchange of information when there is a request from another country. Amid rising international pressure, including from India, Switzerland has been taking steps to share tax information as well as… – Continue reading

Tax survey stresses excessive scrutiny, significance of BEPS

A new survey by E&Y released at its 33rd Annual International Tax Conference, titled “Connecting the dots” uncovered the issues of navigating multiple challenges, led by increased scrutiny and the effects of the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting (BEPS) project. “Tax directors need… – Continue reading

Interest deductions: the new war on base erosion

ITR Correspondent • • • The G20 and OECD’s Base Erosion and Profit Shifting (BEPS) project has rarely been out of the headlines during 2014. At the heart of the BEPS project is the assumption international tax rules make it possible for profits to be taxed in countries that are… – Continue reading

Improving Transparency and Combating Tax Avoidance to Top Agenda of Ninth Forum on Tax Administration, on 23-24 October 2014 in Dublin, Ireland

21/10/14-Tax administrations will play a central role as governments move to implement the measures they have agreed to counter offshore evasion and combat tax avoidance by multinational enterprises. Global initiatives like the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project and the move toward automatic exchange of financial account account… – Continue reading

Cash-strapped countries eye trillions held offshore

Foreign structures are tempting targets for governments, says Vanessa Houlder. When governments around the world embarked on a drive to plug tax loopholes in 2012, the urgency of the move was underpinned by rising tensions over austerity and inequality. Widespread public outrage over alleged tax-dodging by wealthy individuals and multinationals… – Continue reading

BEPS already an issue, says CICA

The Organization for Economic Cooperation and Development’s (OECD) plan for base erosion and profit shifting (BEPS) is already affecting corporations, according to speakers participating in a Captive Insurance Companies Association (CICA) transfer pricing webinar. Polling results during the webinar revealed attendees’ opinions were in line with tax industry surveys indicating… – Continue reading

OECD Secretary-General Angel Gurría Congratulates Latvia on Adopting the “Public Persons Enterprises and Capital Shares Governance Law”

On 16 October, the Saeima (Parliament), in its final reading, passed the “Public Persons Enterprises and Capital Shares Governance Law”  in order to promote more effective governance of companies owned by the state and local governments. The Secretary-General of the Organisation for Economic Cooperation and Development (OECD), Angel Gurría, has… – Continue reading

Luxembourg: Update Of The OECD Model Tax Convention

On July 15th 2014, the OECD published its 2014 update of the Model Tax Convention (“2014 OECD Update”). This update is the outcome of the work accomplished between 2010 and the end of 2013. It does not however take into account the OECD conclusions of the “Action Plan on Base… – Continue reading

Combating tax evasion: Council agrees to extend automatic exchange of information

The Council agreed last tuesday, at a meeting of the Economic and Financial Affairs Council , on a draft directive extending the scope for the mandatory automatic exchange of information between tax administrations, enabling them to better combat tax evasion and to improve the efficiency of tax collection. The proposal… – Continue reading

The changing business model

There has been a lot of press coverage recently around the pricing and tax arrangements of multinationals, in particular Apple, Starbucks and Amazon. In this respect, the EU is undertaking in-depth investigates into these companies to establish whether the companies’ tax arrangements have breached EU State Aid rules. These cases… – Continue reading

LatAm: corruption, tax evasion fuel inequality

These crimes hinder the development of societies, prevent strengthening the legitimacy of democracy SANTIAGO — Corruption and tax evasion are flagrant violations of human rights in Latin America, where they contribute to inequality and injustice in the countries of the region, according to studies and experts consulted by IPS. “Tax… – Continue reading

Irish Budget 2015 – Rate, Regime, Reputation

Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading

PM: Romania wants to become full-fledged OECD member

Romania wants to become a full-fledged member of the Organization for Economic Co-operation and Development (OECD), according to Romanian officials, Prime Minister Victor Ponta and Foreign Affairs Minister Titus Corlățean. The message has been sent to – and received by –the OECD secretary general William Danvers, who was on a… – Continue reading

Nigeria: Transfer Pricing Africa (Part II)

n this second part of our overview of current transfer pricing regulations on the African continent, we focus on relevant provisions in, amongst others, Ghana, Nigeria and Uganda. The Ghanaian Transfer Pricing Regulations, 2012 (L.I.2188) (the Ghanaian Regulations) were introduced by the Ghana Revenue Authority (GRA) on 27 July 2012,… – Continue reading

Strong rules on transfer pricing on agenda in many countries

AMONG several proposals for tax reform, the director-general of the Revenue Department has said the agency would propose an amendment to the Revenue Code concerning transfer pricing, aiming to provide greater clarity on the determination of fair transfer prices. The director-general has indicated that in past years many multinational companies,… – Continue reading

OECD targets diesel and company cars

Taxes on fuel and corporate benefit need to rise significantly, says agency The Organisation for Economic Co-operation and Development (OECD) has launched a war of words on diesel fuel and company cars, claiming that the taxation levels on both are costing governments billions and seriously harming the environment. “The cost… – Continue reading

Fourth protocol to Canada-UK Treaty eliminates withholding tax on arm’s length interest, but preserves tax exemption for gains on disposition of shares and interests deriving value from Canadian real property

On July 21, 2014, the governments of Canada and the United Kingdom signed the fourth protocol (Protocol) amending the Convention between the Government of Canada and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion… – Continue reading

Isle of Man: Crypto-Currencies And The Isle Of Man

The Isle of Man is showing great enthusiasm for crypto-currencies – from the landlord at a popular Douglas drinking hole to the Lieutenant Governor, everyone is talking about digital currency and the potentially huge benefits to the Island. The Isle of Man Financial Supervision Commission (FSC) has announced plans to… – Continue reading

Firms Expect Transfer Pricing Policy Impact From BEPS Project

A vast majority of companies headquartered in the United States expect increased scrutiny of their transfer pricing practices in the short-term as a result of the Organisation for Economic Cooperation and Development’s (OECD’s) base erosion and profit shifting (BEPS) project. A recent EY survey, Connecting The Dots, concluded that 30… – Continue reading

Monaco Signs OECD Multilateral Tax Convention

Monaco has become the 84th jurisdiction to commit to strengthen international tax cooperation through its participation in the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. Welcoming the signing by José Badia, Monaco’s Minister for Foreign Affairs and Cooperation, the Organisation for Economic Cooperation and Development’s (OECD’s) Secretary-General, Angel… – Continue reading

International tax avoidance: Is it eroding Canada’s tax base and how should we respond?

TORONTO , Oct. 2, 2014 /CNW/ – Aggressive international corporate tax avoidance by multinational corporations has become the subject of intense political scrutiny. U.S. politicians have called out some American multinationals, including Apple, Amazon, Starbucks and Google, for relocating profits abroad to avoid U.S. taxes. More recently, politicians accused Burger… – Continue reading

Can the EU tame the multi-national tax dodgers? Why Europe wants to turn the screw on the big guns

The screw is being turned on American companies that use complex structures to whittle down their tax bills. But is the latest EU probe a paper tiger or a game changer? It was supposed to be good news. Amazon’s announcement yesterday that it would hire 1,000 staff was dressed up… – Continue reading

The Big Picture: Wealth and Estate Planning in Argentina

It is said that Argentina faces an economic and political crisis every 10 years. Whenever a crisis arises, Argentinians’ right of ownership is at risk. Devaluation, asymmetric pesification and the current foreign exchange restrictions are a few examples of the challenges we face. What’s more, according to a recent OECD… – Continue reading

India’s challenge on corporate taxation

Foreign investors, not to mention the country itself, need a more stable and predictable regime Foreign companies are depressingly used to run-ins with the Indian taxman. A string of groups, including Vodafone, IBM and Cairn Energy, have been hauled into the dock for not paying their dues in recent years…. – Continue reading

Tax chief to meet Swiss bank heads

Moshe Asher is seeking information about accounts in Switzerland belonging to Israelis. The Israel Tax Authority is stepping up it efforts to combat overseas tax shelters for Israelis. Sources inform “Globes” that Israel Tax Authority director Moshe Asher is expected to travel to Switzerland next week in order to meet… – Continue reading

Ireland Said to Weigh Phasing Out Double Irish Tax Break

Ireland’s finance ministry officials are weighing phasing out a tax device used by multinational companies including Google Inc., according to a person with knowledge of the matter, as the European Union looks into the practice. Ireland is considering whether to eliminate a technique known as the “Double Irish,” which allows… – Continue reading

OECD releases finalised proposals on key tax base erosion concerns

Introduction Action 1: the digital economy Action 2: hybrid mismatch arrangements Action 5: harmful tax competition Action 6: preventing tax treaty abuse Action 8: guidance on transfer pricing and intangible assets Action 13: transfer pricing documentation and country-by-country reporting Action 15: developing a multilateral legal instrument Next steps Introduction On… – Continue reading

ATO alleges complex Chevron scheme slashed tax bill by $258m

Australian tax authorities allege multinational oil giant Chevron used a series of loans and related party payments worth billions of dollars to slash its tax bill by up to $258 million. New documents filed in a long-running dispute in the Federal Court show how Chevron allegedly engaged in a complex… – Continue reading

BEPS, Broken Promises, and What the OECD Can Learn from the WTO About Dispute Settlement Procedures

The question has often arisen whether “international law” is an oxymoron – whether “obligations” in income tax treaties and other international agreements are really binding upon the parties, when they are not buttressed by some sort of enforcement mechanism. That question has never been more relevant in the tax world… – Continue reading

Worldwide: OECD Releases First BEPS Recommendations To G20 In Accordance With Action Plan

As a part of the OECD/G20 project to combat base erosion and profit shifting (“BEPS”), the OECD released the first set of reports and recommendations on September 16, 2014. These reports address seven of the actions described in the 15-point action plan to address BEPS published in July 2013 (the… – Continue reading

Canada: OECD Issues Work On BEPS Actions

The Organization for Economic Cooperation and Development (OECD) has released the first components of its comprehensive plan for creating an agreed set of international rules for fighting base erosion and profit shifting (BEPS) and ending opportunities for double non-taxation. The four model legal instruments and three reports are the first… – Continue reading