Category: Government Bodies

Transfer pricing and arm’s length principle

The dramatic expansion of international trade and development of new business strategies due to globalisation, converted the world into a large global market. In connection with that, companies have been using complex networks of subsidiaries and branches (e.g. permanent establishments) in order to continue most of their operations. The Multinational… – Continue reading

NZ welcomes Cook Islands measures to tackle tax avoidance

NZ welcomes Cook Islands measures to tackle tax avoidance Minister of Revenue Todd McClay has welcomed a decision by the Cook Islands government to implement the ‘Automatic Exchange of Financial Account Information in Tax Matters Agreement’ (AEOI) and says the Cooks Islands and New Zealand will play their part to… – Continue reading

Belgium’s new CFC rule: the ‘Cayman tax’

The Belgian Federal Parliament recently adopted a new controlled foreign corporation provision, known as the “Cayman tax”, that allows Belgian tax authorities to look through low-taxed offshore structures to directly tax their Belgian resident founders and third-party beneficiaries on the structure’s income. Belgium’s introduction of the Cayman tax is in… – Continue reading

Evidence of efforts to help multinationals avoid tax strengthen call for proper EU investigation

Over the weekend, German news magazine, Der Spiegel, reported that over many years EU member states such as Luxembourg and the Netherlands have sabotaged attempts to counter profit shifting to low tax jurisdictions via ‘patent boxes’ under the political leadership of current President of the European Commission, Jean Claude Juncker,… – Continue reading

FRANCE: STATUS OF TRANSFER PRICING DOCUMENTATION, COUNTRY-BY-COUNTRY REPORTING

Legislative proposals being considered in France would require the automatic filing of transfer pricing documentation and, as part of this documentation, country-by-country reporting. STATUS OF PROPOSALS The Finance Committee of the French National Assembly has started its consideration of tax provisions relating to the second part of the Finance Bill… – Continue reading

Implementation problems in connection with the FATCA Agreement

The BMF has application letter sent to the chief financial authorities of the countries associated with the between the Federal Republic of Germany and the United States of America concluded by 31.5.2013 FATCA Agreement. Background Background of extensive, comprehensive 71 pages, application letter from the Federal Ministry of Finance on… – Continue reading

Congressman Introduces Bills to Curb Corporate Tax Inversions and Deferrals

Rep. Mark Pocan, D-Wis., has introduced two pieces of legislation to combat corporate tax inversions and tax deferral. The Corporate Fair Share Tax Act and the Putting America First Corporate Act would prevent corporations from using “tax inversions” to reduce a company’s U.S. tax burden and hide profits overseas. Corporate… – Continue reading

Countries Agree Common VAT Rules For Digital Services

Representatives from more than 100 countries and jurisdictions have endorsed new OECD International VAT/GST Guidelines, which are intended to establish international standards for the “coherent and efficient” application of value-added tax (VAT)/goods and services tax (GST) to the international trade in services. The countries endorsed the new guidelines at the… – Continue reading

Gov’t approves support for SMEs until 2020

Transportation and other issues also taken up by the Cabinet Prague, Nov 9 (ČTK) —The Czech government today approved the Industry and Trade Ministry’s program Expansion, under which Kč 9.5 billion (€350 million) should be provided in support of small and medium-sized enterprises until 2020, Deputy Prime Minister Pavel Bělobrádek… – Continue reading

Tax breaks must end, says economist

Economist and policy consultant, Avernash Persaud is urging government to remove concessions for foreign investors, a similar advice proffered by the International Monetary Fund (IMF). Persaud said government should instead focus its attention on infrastructure development. Persaud, who has assisted in policy development in countries like Singapore, said investors will… – Continue reading

Deloitte Poll: US Business Executives Cite Concerns and Priorities for OECD’s Final BEPS Package

NEW YORK, Nov. 9, 2015 /PRNewswire/ — Business executives cited an increased compliance burden as their biggest concern with the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting initiative (37.7 percent), according to an October Deloitte poll. Other concerns included double taxation of income (17 percent) and… – Continue reading

Transfer pricing drains us of tax blood

Transfer pricing by multinationals has cost South Africa an estimated R250 billion over three years and, with it, lost tax revenue. This is according to Sunia Manik, group executive for the large business centre at the SA Revenue Service (Sars), adding that it was being done through “service payments” made… – Continue reading

The ‘end’ of tax evasion

The UK is one of several countries to introduce voluntary disclosure schemes. More people are coming forward to regularise their affairs as they realise there is nowhere left to hide in this new world of tax transparency. Tax authorities and financial institutions are gearing up for the new automatic exchange… – Continue reading

Europe May Not Be a Tax Haven for U.S. Multinationals Much Longer

FRANKFURT (The Street) — Europe’s allure as a tax haven for U.S. multinationals may be coming to an end. That’s because European Union regulators are closing up tax loopholes that U.S. companies have been enjoying for years. The first two to feel the heat are Starbucks (SBUX – Get Report)… – Continue reading

Tax-avoidance Gibraltar firm behind anti-EU campaign group

Leave.EU, supported by Ukip and financed by a multimillionaire, vies to lead Britain’s exit from Europe A leading campaign group seeking to take Britain out of the European Union was set up by an offshore company that offers tax avoidance services to “high net worth individuals”, the Observer can reveal…. – Continue reading

Tax system slow to adapt to digital economy’s rise

LOST REVENUE:A lack of regulations on taxing cross-border Web-based content and services providers puts their local peers at a disadvantage, Ernst & Young said The nation’s tax system is relatively behind developed markets in adapting to the proliferation of the digital economy, which has resulted in lost revenues for the… – Continue reading

Commentary: In face of ‘tax haven’ attack, CARICOM must unite

No member state of the Caribbean Community (CARICOM) ranks among the top 20 jurisdictions worldwide for financial secrecy. The United States of America (at number 3), Germany (8), Japan (12) and Britain (15), all rate as bigger tax havens than any CARICOM jurisdiction, according to the Tax Justice Network (TJN),… – Continue reading

US fuss about Irish tax deals just election fever, says ex-Apple CEO

The recent corporation tax controversy highlighted by US presidential hopefuls Hillary Clinton and Donald Trump is not damaging Ireland’s reputation as a place to do business, said the former chief executive of Apple, John Sculley. According to Mr Sculley, the controversy is simply part of US election fever. Known as… – Continue reading

In face of ‘tax haven’ attack, CARICOM must unite | Sir Ronald Sanders

ST. JOHN’S, Antigua, Friday November 6, 2015 – No member state of the Caribbean Community (CARICOM) ranks among the top 20 jurisdictions worldwide for financial secrecy. The United States of America (at number 3), Germany (8), Japan (12) and Britain (15), all rate as bigger tax havens than any CARICOM… – Continue reading

Bleak growth exposes malaise of revenue shortfalls

First it was the scourge of public sector corruption, until now the mortifying spectacle of South Africa’s post-apartheid transition. Now, with the ground shifting beneath the world’s sclerotic economy – and the past few years have produced more tremors than ever in the 21 years of democracy – it’s a… – Continue reading

POLAND: EXPANDED TRANSFER PRICING, COUNTRY-BY-COUNTRY REPORTING ENACTED

New law in Poland expands the requirements for transfer pricing documentation, and includes country-by-country (CbC) reporting. The new provisions essentially reflect the recommendations made in Action 13 the OECD’s base erosion and profit shifting (BEPS) project, and provide for CbC, master file and local file reporting. The legislation was passed… – Continue reading

OECD BEPS Heralds Big Changes for Tax Pros and Corporate Treasurers

The Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting action plan is likely to have a major impact on tax planning at multinational corporations by both tax professionals and corporate treasurers. Tom Driscoll, U.S. managing partner for international tax, transfer pricing, and indirect tax at Deloitte Tax… – Continue reading

Marco Rubio’s Billionaire Backer Likes to Sue Poor Countries and Put Profits in Tax Havens

Paul Singer has a good track record as a money manager. In 1995, he bought $20 million worth of Peruvian debt at a discounted price of $11.4 million, then forced Peru’s government, through lawsuits, to eventually pay nearly five times his initial investment — some $58 million. In 2002 and… – Continue reading

Changes to the BVI Anti-Money Laundering Regime

The BVI has announced amendments to its Anti-Money Laundering (AML) regime in order to ensure continued compliance with developing international standards on transparency and AML regimes. Amendments to the legislation have recently been published (Code of Practice and Regulations) and the proposed changes are to take effect on 1 January… – Continue reading

Seychelles rated ‘largely compliant’ by OECD – continued vigilance and reforms needed to uphold status, says finance minister

(Seychelles News Agency) – Seychelles’ efforts to comply with the widely-recognised Organisation for Economic Co-operation and Development (OECD)’s regulations on the sharing of tax information has led the island nation’s jurisdiction to be rated ‘largely compliant’. This follows a re-assessment of the island nation’s ‘practical implementation’ of its legal and… – Continue reading

Germany: tax court prevents tax office from exchanging information with E6 countries in relation to digital economy

On September 7, 2015, the local tax court of Cologne (the “Court”) issued an injunction against the German Federal Central Tax Office (“FCTO”) to prevent the FCTO from conducting a coordinated exchange of information with the E6 countries Canada, Great Britain, France, Australia and Japan, which aimed at gathering intelligence… – Continue reading

BEPS and funds

On 5 October 2015 the OECD published the final package of recommendations to reform the international tax system – the “BEPS” Project. Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations… – Continue reading

Abolition of Luxembourg IP box regime

On 14 October 2015, the Luxembourg Minister of Finance presented a bill to Parliament on the state budget for 2016. This bill contains several proposals affecting corporate taxpayers. One of the main proposals is the abolition of the intellectual property regime. Similar tax relief systems, known as “IP box” or… – Continue reading

LuxLeaks: Little change in tax avoidance loopholes one year on from revelations

British MEP Anneliese Dodds has accused national governments of hampering progress in tackling corporate tax dodging, warning that EU capitals are “far too focussed on their own self-interests”. On the anniversary of the breaking of the LuxLeaks scandal, Dodds said MEPs had made some progress in stamping out aggressive tax… – Continue reading

Knowledge Development Box – to encourage more innovation

Since Minister Noonan announced in October 2014 that Ireland would introduce a “best-in-class” Knowledge Development Box (“KDB” ), there has been a lot of speculation about ‘how low would he go’. Budget 2016 announced that the rate of tax which will apply for income qualifying under the new KDB will… – Continue reading

‘SA is bleeding billions’

JOHANNESBURG – South African has lost R250 billion in the form of service payments over a three-year period, highlighting the significant risk base erosion and profit shifting (BEPS) is posing to the country’s tax base, a South African Revenue Service (Sars) official has said. Almost R80 billion of this were… – Continue reading

AUSTRALIA: ARE INVESTMENT ENTITIES EXCLUDED FROM “GROUP” FOR COUNTRY-BY-COUNTRY REPORTING?

A question being considered in Australia—concerning country-by-country (CbyC) reporting—is whether an investment entity is to be excluded from the “group” for CbyC reporting purposes. A preliminary position being advanced is when an entity is not required to prepare consolidated financial statements for financial reporting purposes, then it would be excluded… – Continue reading

Liechtenstein Rated “Largely Compliant” By OECD

Liechtenstein’s Prime Minister, Adrian Hasler, has welcomed recognition from the international community for its efforts to improve tax transparency. The Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) recently rated Liechtenstein “largely compliant” with Organisation for Economic Cooperation and Development (OECD) standards on tax transparency…. – Continue reading

Eurodad Identifies Surprising Haven Nations for Tax Evasion and Money Laundering

The European Network on Debt and Development (also known as “Eurodad”), a network of NGOs, has issued a recent report identifying European nations that have served as havens for tax evasion and money laundering. According to the report, Germany, Luxembourg, and Spain are among the most egregious offenders. By turning… – Continue reading

Apple’s US returns indicate substantial rise in Irish tax paid

Technology company made the largest profit in its history in year to end of September Apple’s latest annual report indicates a substantial increase in the amount of tax it may be paying in Ireland. The latest annual report from Apple, filed last week in the United States, indicates a substantial… – Continue reading

UK takes two-faced approach to tax, new report suggests

The UK government has a ‘Janus-faced’ approach to tax, a new report suggests: promising an increasingly intolerant approach to evasion and avoidance while being an aggressive participant in global tax competition and tolerating the UK tax havens which facilitate financial crime across the world. The report, Fifty Shades of Tax… – Continue reading

‘Patently False’: Bahamas Not Violating Tax Rules

A former finance minister yesterday slammed as “patently false” suggestions by a prominent tax advocacy group that the Bahamas is “disregarding the rules” and flouting global information exchange and transparency standards. James Smith, also an ex-Central Bank governor, hit out at the Tax Justice Network after its 2015 Financial Secrecy… – Continue reading

Blacklisted HK: The Latvian Case

The blacklisting of Hong Kong by the European Union is over for the moment with Spain explaining to the EU it didn’t have HK on its list. In the course of investigation, Harbour Times receives a quick response from the Latvian embassy in Beijing to clarify their stance on Hong… – Continue reading

Sixteen States’ Tax Transparency Frameworks Reviewed

Sixteen peer review reports were released at the recent plenary meeting of the OECD Global Forum on Transparency and Exchange of Information for Tax Purposes on October 29-30, 2015. The release of the reports follows reviews of those territories’ legislation for the exchange of tax information and their frameworks for… – Continue reading

Global Forum makes strides toward tax transparency

The timely and effective implementation of the automatic exchange of tax information was a key theme during the Oct. 29-30 meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes held in Bridgetown, Barbados. The meeting, which brought together delegates from the Global Forum’s 128 member… – Continue reading

Two unexpected countries could be havens for money laundering and tax dodging

Eurodad’s country comparison table, showing how each of the studied countries fared in the evaluation of four tax-related categories. Germany, Luxembourg, and Spain are egregious offenders in “supporting an unjust global tax system,” according to a new report from the European Network on Debt and Development (Eurodad), a network of… – Continue reading