MUMBAI: India’s forthcoming budget may draw from some of the recommendations, especially in the realm of transfer pricing, contained in the final package of ‘Base Erosion and Profit Shifting’ (BEPS) measures, rolled out in October. Certain anti-abuse measures, such as thin capitalization, which for tax purposes disallows interest payments beyond… – Continue reading
Introduction Facts Decision Introduction The European Court of Justice (ECJ) recently ruled that the system of interim taxation for Austrian private foundations does not comply with EU law.(1) A special feature of private foundations is the so-called ‘interim tax’ – a type of corporate income tax. Pursuant to Section 13(3)… – Continue reading
On 18 June 2013, the Progressive led government issued a press release titled, “Cayman’s Action Plan Includes Beneficial Ownership”. The press statement came on the heels of the UK taking over the Presidency of G8, at the 17-18 June 2013 G8 Summit in Northern Ireland. The most interesting part of… – Continue reading
The European Commission has asked the German Government to amend its inheritance tax (IHT) law after finding that current rules discriminate against those who are not resident in Germany for tax purposes in certain situations. Under German IHT law, a special maintenance allowance is granted to surviving spouses or registered… – Continue reading
Ownership of Kildrummy Estate creates legal block for police investigators POLICE INVESTIGATIONS into wildlife crime failed in the face of a bureaucratic nightmare identifying the landowner behind a complex structure of offshore land secrecy. The conviction of gamekeeper George Mutch for wildlife crimes committed in 2012 on Kildrummy Estate opened… – Continue reading
The governments of Malta and the Caribbean island of Caraçao have signed a treaty, which both sides say will prevent tax evasion and the double taxation of companies operating in both jurisdictions. In line with internationally agreed standards, Malta’s finance minister Edward Scicluna and his counterpart from Caraçuo Jose Jardim… – Continue reading
The OECD/G20 project on BEPS provides governments with solutions for closing the gaps in existing international rules that allow corporate profits to artificially shift to low or no-tax environments, where little or no economic activity takes place. Finance Ministry today said it is prioritising implementation of certain Base Erosion and… – Continue reading
Plans that would effectively end the UK’s non-domicile status for tax purposes have the potential to do more harm than good and could be contrary to EU law, according to the Institute of Chartered Accountants. The changes, announced by chancellor George Osborne in the 2015 summer budget, mean that non-UK… – Continue reading
Malta recently ranked first for efficiency in transposing directives into national legislation – but the chairman of Finance Malta, Kenneth Farrugia, believes that the pace of innovation needs to accelerate. “We claim to be nimble, but we need to push it much more. Innovation needs to be much faster paced…. – Continue reading
Officials from the ministries of finance and economy of five CEE countries (Czech Republic, Hungary, Poland, Romania and Slovakia) have called for a joint approach to combat VAT fraud and increase VAT collection in a conference hosted by PricewaterhouseCoopers (PwC) in Budapest on Thursday. According to the EU Commission data,… – Continue reading
On November 19, 2015 the European Commission published the key decisions of its November infringement package. One of the key decision mentioned is the Commission’s decision to request Germany to bring its inheritance tax rules on special maintenance allowances in line with EU law. According to a press release issued… – Continue reading
Compare this to the 2601 tax-related incarcerations in 2014 in the US. Jail for tax evasion is common in that country. The most well- known case is that of the gangster Al Capone who spent 7 years in jail as far back as 1932 to 1939. In recent years, actor… – Continue reading
“What’s the best way to rob a bank? Start one.” Many people have heard that old saw. But it’s no longer accurate. The best way to rob a bank is to control a government … any old government will do these days. It wasn’t always like that. You see, for… – Continue reading
On November 19, 2015 the European Commission published the key decisions of its November infringement package. One of the key decision mentioned is the Commission’s decision to request the Netherlands to amend the Limitation on Benefits (LOB) clause in the Dutch-Japanese Tax Treaty for the Avoidance of Double Taxation, which… – Continue reading
CANBERRA – Several multinational companies have approached the Australian Taxation Office to negotiate before the Coalition Government’s tougher anti-avoidance laws take effect in January, tax commissioner Chris Jordan has said in opening remarks to the Senate inquiry into corporate tax avoidance. While not naming the companies, Jordan said he expects… – Continue reading
Nigeria’s tax authority—the Federal Inland Revenue Service—has incorporated into its tax audit procedures certain of the recommendations included in the OECD’s base erosion and profit shifting (BEPS) project. For instance, the tax authority is scrutinizing transactions between Nigerian subsidiaries and their foreign related parties, especially those related parties located in… – Continue reading
Employees in tax functions need to fundamentally change the way they use and gather data if they are to meet the growing demands on business of tax transparency, reform and technology enabled decision making. PwC’s latest research into the Tax function of the future – Unlocking the power of data… – Continue reading
In recent days, the new Speaker of the House Paul Ryan (R-Wis.) signaled a priority for international tax reform in 2016. And if the newest recommendations from the Organization of Economic Cooperation and Development (OECD) are any indication of what’s ahead on the global tax scene for American businesses, it… – Continue reading
Earlier this week the heads of state of the 20 largest global economies have agreed to adopt the 15 BEPS action points in their respective countries. Ample reason to take a closer look at the details and implications of one of the most far-reaching upcoming tax adjustments. Action 4 of… – Continue reading
Measures Will Impact Financial Services, Investment Fund, Aviation Leasing and Other Sectors G20 finance ministers last week finally approved the wide-ranging “BEPS” reforms to the international tax system. The measures include a proposed new OECD treaty definition of “Permanent Establishment” under which the mere negotiation of contracts could create a… – Continue reading
Tax administrators want to maximise the amount of revenue collected without stifling the county’s competitiveness as a business destination. How should ASEAN countries navigate changing international conditions to meet this goal? By Rebecca Tan – As Benjamin Franklin once famously said, “In this world, nothing can be said to be… – Continue reading
Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading
Latest developments under the Base Erosion and Profit Shifting (BEPS) initiative of the Organisation for Economic Co-operation and Development (OECD) was one of the key points of a recent four-day visit by KPMG’s global leader for Transfer Pricing Services Sean Foley to Vietnam. He shared the issue with Vietnam’s General… – Continue reading
If statistics are anything to go by, today India is the world’s fastest growing economy at 7.3% in 2015, outstripping the global average of 3.1%. With a new government in the centre, we do seem to be riding high on the growth trajectory. The Modi government has certainly done its… – Continue reading
Finnish companies continue to take advantage of legal tax planning to shelter their profits from taxation. According to Yle’s Ajankohtainen kakkonen current affairs programme, state-owned firms are among those that have been dragging their feet on reporting income from their foreign subsidiaries. The European Union is making an effort to… – Continue reading
18 November 2015 – The Group of 20 (G20) leaders have called for more collective action to achieve strong, sustainable and balanced growth that can be universally beneficial. In a communique issued at the end of the summit, the leaders agreed that not only do they have to do more… – Continue reading
The new tax treaty signed between Australia and Germany on 12 November 2015 is the first tax treaty Australia has signed that comprehensively incorporates the proposals in the OECD base erosion and profit shifting (BEPS) final recommendations. Some notable BEPS-related changes in the new Australia and Germany treaty include: The… – Continue reading
American Innovation Matters (AIM), a coalition of companies that includes Cisco, Boeing, Intel, Oracle and Facebook, has released a statement pushing for the introduction of a US patent box, or an “innovation box” as it is known in the United States. The statement looks at the endorsement on November 16… – Continue reading
Google is said to have evaded paying an estimated $1.3 billion earned from selling apps in Korea based on the argument that their server is based in Ireland. The so called ‘Google Tax’, also known as the Base Erosion & Profit Shifting (BEPS) regulation, has been adopted this week by… – Continue reading
Policies on perks, more bilateral pacts can help generate funds for growth: Accounting firm Singapore’s tax system can be improved to ensure the country can generate the funds needed for long-term growth and development, according to a white paper from accounting giant PwC yesterday. It called for policies that ensure… – Continue reading
As early adopters of the new global standard for the automatic exchange of information; Jersey and Spain signed a tax information exchange agreement (TIEA) on Tuesday. The agreement was signed at the Spanish Embassy in London by Jersey’s assistant chief minister, senator Philip Ozouf, who said: “We attach great importance… – Continue reading
Tax Commissioner Chris Jordan says multinationals are already approaching the Australian Taxation Office to negotiate before the Turnbull government’s tougher anti-avoidance laws take effect in January, and he expects the office to reap $1.1 billion from them. We at the ATO acknowledge Australia needs investment by foreign companies in infrastructure… – Continue reading
Global tax is set to face the biggest shake up ever that will affect every saver and investor with accounts in any of the world’s major financial centres. Financial firms and governments are readying to start the Common Reporting Standard (CRS) from January 1, 2016. CRS is a souped up… – Continue reading
PwC Australia Australian Taxation Office New or updated materials on ATO website, including: Decision impact statement on McGrouther & Anor v Commissioner of Taxation case concerning whether a taxpayer can waive or withdraw a notice given to the Commissioner under s14ZYA(2) of the Taxation Administration Act 1953 (requiring the Commissioner… – Continue reading
KPMG in Kuwait discusses plans to implement a tax on business profits, changes to the Kuwait tax authority’s (KTA) approach to deemed permanent establishments, and Kuwait’s shift away from tax holidays toward tax credits to attract foreign direct investment. TAXATION OF COMMERCIAL PROFITS Based on recent local media reports1, KPMG… – Continue reading
One of the amendments proposed in the Taxation Laws Amendment Bill (TLAB), relates to the revision of the definition of “immovable property.” This definition is significant when considering the potential tax liability of non-resident persons, especially when it comes to capital gains tax (CGT). Paragraph 2 of the Eighth Schedule… – Continue reading
Globally, taxpayers are becoming more interdependent, and engage in cross-border financial activities with more regularity. With this, comes the need for enhanced co-operation and understanding across countries on issues such as tax administration and transparency, to curb tax evasion and ensure a fair allocation of taxes to tax jurisdictions. “The… – Continue reading
MEPs grilled eleven multinational companies on their corporate tax practices in a five-hour debate with the Special Committee on Tax Rulings on Monday. These companies had declined the committee’s first invitation to appear before it, but later changed their minds and accepted its last chance invitation. Of the 13 original… – Continue reading
Brussels – Google and Facebook were among US companies facing questions on Monday from European Union lawmakers about their tax-reducing techniques, a month after regional antitrust regulators raised the stakes by ordering Starbucks and a Fiat Chrysler Automobiles NV unit to repay millions of euros in back taxes. The queries… – Continue reading
Fund houses and R&T agents have already started alerting investors to furnish Fatca and KYC details Mutual fund (MF) investors have to submit declarations to their fund houses to comply with the Foreign Account Tax Compliance Act (Fatca), which was passed in the US in 2010 (read more on this… – Continue reading
A Ministry of Finance decree published on 11 November 2015 provides follow-up guidance concerning advanced tax rulings issued by the Dutch tax administration. BACKGROUND Adopted in July 2014, an amendment to the EU Parent-Subsidiary Directive addresses mismatches resulting from hybrid financing, and involves the inclusion of an anti-hybrid provision. Under… – Continue reading
President Park Geun-hye called Monday for a careful adjustment of monetary policies of advanced countries amid lingering worries over a potential Fed rate hike. Last month, the U.S. Federal Reserve kept interest rates at near zero due to global headwinds but suggested that it could raise rates by the end… – Continue reading
HM Revenue and Customs (HMRC) has published a brief on how the UK will implement the G20’s High Level Principles on Beneficial Ownership Transparency. The brief explains that the UK will require companies to report beneficial ownership information to a central register. This register will be publicly accessible and is… – Continue reading
On November 10th 2015, the European Council announced that the EU Savings Directive 2003/48/EC (EUSD) has been repealed in order to eliminate the overlap with other legislation developed in the aspect of preventing measures of tax evasion. Brief Background The 2003 EUSD, which originally came into effect on 1 July… – Continue reading
The FINANCIAL — Employees in tax functions need to fundamentally change the way they use and gather data if they are to meet the growing demands on business of tax transparency, reform and technology enabled decision making. PwC’s latest research into the Tax function of the future – Unlocking the… – Continue reading
MELAKA, Nov 17 (Bernama) — The Inland Revenue Board (IRB) has highlighted the transfer pricing (TP) and abuse of treaties in base erosion and profit shifting (BEPS) issues at the 36th Commonwealth Association of Tax Administrators Conference (CATA) here today. IRB, in a statement today, said CATA members were serious… – Continue reading
Hong Kong (HKSAR) – The Financial Secretary, Mr John C Tsang, arrived at Bucharest, Romania today (November 17, Bucharest time), for his two-day visit to strengthen economic and trade ties between Hong Kong and Romania. Mr Tsang first held a meeting with the Representatives of the Romanian Banking Association. Mr… – Continue reading
Foreign investors are still concerned about the retrospective taxation in India, but the concerns have alleviated a little due to assurances by the government, says John Hobster, global head (transfer pricing), EY. He tells Dilasha Seth that in terms of transfer pricing, things are changing in India not only at… – Continue reading
On 30 October 2015, the Global Forum on Transparency and Exchange of Information for Tax Purposes published a supplementary peer review report for Luxembourg. Luxembourg, which was rated “Non-Compliant” in November 2013, has since implemented a number of recommendations made by the Global Forum, leading to an upgrade of its… – Continue reading
The need for robust, well-informed intangible asset valuations for the purpose of transfer pricing is becoming ever more invaluable for MNEs TRANSFER pricing has been the buzz-word of the moment with extensive media coverage in recent years of multinational enterprises (MNEs) repositioning profits to more favourable tax jurisdictions. This movement… – Continue reading
