The Organization for Economic Co-operation and Development’s (OECD) Action Plan 6 on the Base Erosion and Profit Shifting (BEPS) initiative recognizes that countries need to incorporate sufficient safeguards in their tax treaties and domestic rules to protect against practices that take advantage of the differences in national tax systems and… – Continue reading
As countries share more information, opportunities to squirrel away cash abroad will continue to narrow AMONG the sins that have most angered the austerity-weary everywhere is the use of undeclared offshore accounts to stash the wealth of the rich. Greeks were particularly enraged when data stolen from Swiss banks showed… – Continue reading
A Labour government would push for UK overseas territories to be put on an international blacklist if they refuse to co-operate with a drive against tax avoidance, Ed Miliband has told them. In a letter to their leaders, he said they would have six months to compile a public register… – Continue reading
The OECD will present the latest developments in the OECD/G20 project to combat base erosion and profit shifting (BEPS) by multinational enterprises during a G20 Finance Ministers meeting on early next week (9th/10th February) in Istanbul. OECD and G20 countries have agreed three key elements that will enable implementation of… – Continue reading
A swath of changes to corporation tax in the European Commission’s pipeline topped the Taoiseach’s agenda when he met the president of the European Commission, Jean Claude Juncker officially in Brussels. New rules that would force every country to make public the tax arrangements with larger companies, including multi nationals… – Continue reading
The Public Accounts Committee (PAC) has launched an attack on the tax industry in the light of evidence presented by Big Four firm PwC In a 17-page report on tax avoidance and large accountancy firms, the PAC blasts the tax industry as being unable to regulate itself and calls on… – Continue reading
G20 finance ministers will hear about the OECD’s three-pronged approach to implementation of the BEPS Action Plan at their meeting in Istanbul on Monday and Tuesday of next week (February 9 and 10). The OECD, which is leading the work, outlined today what has been agreed so far with the… – Continue reading
Government’s updated strategy aims to add 10,000 jobs to Dublin ’s international financial hub When the International Financial Services Centre began life in 1987 it had just three companies, employing 55 people. If a strategy drawn up for the Government comes to fruition, some 10,000 direct net new jobs will… – Continue reading
The European Commission is currently conducting in-depth investigations into whether national tax rulings breach the EU’s competition rules. Whilst the spark for these investigations was the “Luxleaks” scandal, in December 2014 the Commission sought information from all Member States as part of a much larger campaign to attack what the… – Continue reading
Technology giants Apple and Google have said in their submissions to the federal inquiry into corporate tax avoidance that they support international changes to global tax rules to stop profit shifting, but have warned of the risk of Australia acting alone, saying it would cost heavily in local jobs and… – Continue reading
A recent report detailing how Africa lost $US1-trillion in the last 50 years through illicit financial flows of money has raised questions about it’s abilities to curb fraud evasion and other means of corporate profit hiding. It has also sparked interest in holding multinational corporates, which are mainly responsible for… – Continue reading
MUMBAI: The Mumbai bench of the tax tribunal has clarified that additional tax liability cannot be claimed from competitive industries in the name of location savings arising out of the country’s low-cost manufacturing base. The ruling may benefit pharmaceutical, auto, IT and IT-enabled companies, among others, that are engaged in… – Continue reading
Korean Gov’t to Tax Google, Facebook Like Domestic Companies orea is moving to impose taxes on foreign ICT giants such as Google, Apple, and Facebook. To this end, Ruling Saenuri Party lawmaker Hong Ji-man tabled revisions to the Income Tax Act and the Corporate Tax Act in December last year…. – Continue reading
Google has told the Australian parliament that it would prefer issues around taxation of multinational corporations to be dealt with by the G20 or the Organisation for Economic Co-operation and Development (OECD), rather than have individual countries attempt to go it alone. The Australian government is attempting to tackle profit… – Continue reading
The Confederation of British Industry (CBI) has warned the UK Government that significant changes are needed to its proposed diverted profits tax legislation, to ensure that the regime does not capture genuine commercial arrangements. In his 2014 Autumn Statement, Chancellor George Osborne announced plans to levy a 25 percent diverted… – Continue reading
On February 2, the Obama Administration released its fiscal year 2016 budget (FY 2016 Budget). The hallmarks of the FY 2016 Budget are proposals that would impose (i) a minimum tax on the current foreign earnings of U.S. corporations and their controlled foreign corporations (CFCs) and (ii) a one-time 14%… – Continue reading
The government is planning to devolve power over the corporation tax rate to the Northern Ireland assembly. This bold and unprecedented move is intended to enable Northern Ireland to compete with the Irish Republic’s headline rate of 12.5%, and follows the agreement that Scotland should set its own rate for… – Continue reading
THE European Union (EU) will not pursue a probe of national programmes that create tax breaks for research and development, giving a boost to drug and technology companies that generate revenue from patents. The EU’s hands were tied by a 2008 decision to approve a “patent box” tax break in… – Continue reading
Claims by the European Commission that UK rules make it “virtually impossible in practice” for companies to claim tax relief on losses by subsidiaries in other member states should be dismissed, the EU’s highest court has ruled.03 Feb 2015 Corporate tax EU and UK competition law EU & Competition Tax… – Continue reading
In 2014, China continued to develop its taxation system affecting domestic and crossborder transactions. This “Legal Flash – Special Edition 2014” highlights the most significant tax updates of the year. Please see our monthly legal flashes for more information and analysis here. Taking a step-forward on anti-avoidance provisions, the State… – Continue reading
The European Commission has turned a blind eye to secretive tax deals that Ireland and other countries have been doing with multinationals for decades. Only after complaints from the US did it launch investigations into the most high-profile cases — Apple in Ireland, Starbucks in the Netherlands, and Amazon in… – Continue reading
The ultimate owners of firms would have to be listed in central registers in EU countries, accessible to people with a “legitimate interest”, such as investigative journalists and other concerned citizens, under a deal struck by Parliament and Council negotiators on a draft EU anti-money laundering directive on Tuesday. The… – Continue reading
(Bloomberg) — The European Union is investigating Belgium’s tax deals with multinational corporations, potentially dragging dozens more companies into widening probes of sweetheart fiscal pacts handed out by national governments. Building on investigations of Apple Inc. in Ireland and Amazon.com Inc. in Luxembourg, the European Commission is targeting Belgium’s so-called… – Continue reading
NEWS: Spain’s Foreign Minister said “it was fine” for Fabian Picardo to speak in Madrid: “as long as no one forces me to listen”. The Chief Minister was introduced by the British Ambassador. In a breakfast speech in central Madrid to a room filled with some 250 politicians, businessmen, diplomats… – Continue reading
(Reuters) – The European Commission is investigating a Belgian system allowing companies to reduce their tax bills significantly, it said on Tuesday, widening its inquiry into tax deals struck with multinationals across the European Union. The Commission, which rules on competition and subsidies in the European Union, said deductions granted… – Continue reading
The United Nations (UN) has plumped for greater cooperation among countries to put in place a set of safeguards and rules for tax reforms the world over in the bleak backdrop of extant rules and conditions, “particularly regarding illicit flows, as well as tax avoidance” often limiting what governments can… – Continue reading
Progress continues to be made in the BEPS project, with the release in September 2014 of the “2014 Deliverables” and a raft of discussion drafts published during the autumn. Here is a summary of all the recent developments. Within the framework of the BEPS (Base Erosion and Profit Shifting) action… – Continue reading
Ireland has been ranked among the least complex business destinations for multinationals, and its appeal has improved as a result of recent international tax policy changes, according to a new study. The study from the TMF Group ranked 81 jurisdictions across Europe, the Middle East, Africa, Asia-Pacific, and the Americas… – Continue reading
Business industry feedback on BEPS discussion drafts, including comments from BIAC, TEI, Reed Elsevier, Volvo and Siemens, suggests that the OECD has done little to quash taxpayer concerns over double taxation and dispute resolution. The OECD’s BEPS project was the TP topic of 2014 and will undoubtedly retain the top… – Continue reading
Weak governance means Africa loses more than $50bn each year in unpaid taxes and money laundering, a new report has found. The analysis, published jointly by the African Union and the United Nations Economic Commission for Africa, concluded that a lack of financial transparency and difficulties in obtaining systematic data… – Continue reading
Guernsey’s forward-thinking approach to international regulatory requirements has aided the success of its funds industry and raising its profile as an international finance centre, according to a panel discussion at the Guernsey Funds Masterclass in London. Panellists discussed the implementation of regulations like such as the Alternative Investment Fund Managers… – Continue reading
Panellists at a Guernsey funds technical masterclass in London have praised the jurisdiction for its “progressive nature” in tackling international regulatory developments. Delegates were told that Guernsey’s response to initiatives such as the Alternative Investment Fund Managers Directive (AIFMD), Markets in Financial Instruments Directive (MiFID) II, the Foreign Account Tax… – Continue reading
The draft legislation published on 10 December 2014 (see here) devotes almost 30 pages to the new “diverted profits tax” (DPT), which from 1 April 2015 will introduce a new tax at a rate of 25% to profits generated by those multinational corporate groups who, in the eyes of the… – Continue reading
New Delhi: Multinational companies operating in India will soon have to disclose details of their operations at the country of residence and their revenue income to the Income Tax authorities. The Budget for 2015-16 may contain provisions relating to the Global Base Erosion and Profit Shifting (BEPS) rules, which are… – Continue reading
NEW DELHI: Multinational companies operating in India will soon have to disclose details of their operations at the country of residence and their revenue income to the Income Tax authorities. The Budget for 2015-16 may contain provisions relating to the Global Base Erosion and Profit Shifting (BEPS) rules, which are… – Continue reading
According to an estimate by the European Commission, the EU is at least 1,000 billion euros out of pocket because of tax evasion and avoidance. A major problem related to tax evasion is that in many cases it does not involve any illegal activities but is regarded as tax planning… – Continue reading
The present French Tax Update will focus on (i) the most salient features of the new double tax treaty signed by the People’s Republic of China (China) and France on November 26, 2013 (New DTT), (ii) the new double tax treaty signed by Singapore and France on January 15, 2015,… – Continue reading
IN LAST WEEK’S column we talked about the OECD’s BEPS Action Plan on Hybrid Mismatch Arrangements. This week’s column focuses on the OECD’s Action Plan on Harmful Tax Practices (HTP). As the world economy continues the process of globalization and technological advances, tax authorities from various jurisdictions are inevitably faced… – Continue reading
A double tax treaty (“DTT”) was signed between Cyprus and Lithuania in June 2013. The treaty which follows the OECD Model Convention for the avoidance of Double Taxation on Income and on Capital has been ratified by the two Contracting States and has entered into force as of 1 January… – Continue reading
A Sunday Mirror investigation has found Apple, Facebook, Amazon, Google, Ebay and Starbucks has paid less than one per cent tax Six of the world’s biggest companies paid just 0.3 per cent of their UK earnings in corporation tax last year, a Sunday Mirror probe has found. We have examined… – Continue reading
Feb 1 (Reuters) – The Chinese government’s vow to increase tax scrutiny of foreign companies has sent firms rushing to tax advisors ahead of the implementation on Sunday of new rules designed to rein in cross-border tax avoidance. Tax professionals and business lobbies alike have welcomed the move as an… – Continue reading
The Government of Spain has announced that new country-by-country (CbC) reporting obligations will be effective in Spain for tax periods beginning on or after January 1, 2016. The CbC reporting obligation, which was announced on January 20, 2015, will technically apply from 2017, when tax returns for the previous year… – Continue reading
The EU won’t limit how much it seeks to claw back from companies including Apple and Amazon that are ensnared in tax probes if controversial deals with national governments are overturned. The European Commission is currently probing the tax arrangements between Apple and Ireland, alleging that a deal was struck… – Continue reading
When a crowd of angry Americans threw 45 tonnes of tea into Boston Harbor in 1773, their concern was the under-enforcement of the principle of ‘no-taxation without representation’ — that governments should not impose fiscal obligations on their citizens without them having a saying on it. More than two centuries… – Continue reading
When a crowd of angry Americans threw 45 tonnes of tea into Boston Harbor in 1773, their concern was the under-enforcement of the principle of ‘no-taxation without representation’ — that governments should not impose fiscal obligations on their citizens without them having a saying on it. More than two centuries… – Continue reading
Cash reserves held outside the US for tax reasons by US multinationals are “likely to fuel a big increase in M&A activity over the next year”, said Eloise Walker a tax expert at Pinsent Masons, the law firm behind Out-law.com.30 Jan 2015 Corporate Tax Corporate tax International tax M&A Advanced… – Continue reading
On January 27, 2015, the Council of the European Union formally adopted a decision to add a binding anti-abuse clause to the EU Parent-Subsidiary Directive. The anti-abuse clause, which was agreed by the Economic and Financial Affairs Council on December 9, 2014, aims to prevent misuse of the Directive and… – Continue reading
Santo Domingo.- Internal Taxes Agency director Guarocuya Felix on Thursday warned that Dominican Republic must soon dismantle the barriers which limit the automatic access to information of the financial sector’s taxpayers, because despite the Arbitration Court resolution to break banking secrecy when the tax administration so requires, the information doesn’t… – Continue reading
European Parliament President Martin Schulz expressed optimism on Thursday about a solution being found between Greece and its lenders, while stressing support for the new government’s plans to tackle tax evasion. Schulz was in Athens to hold talks with Prime Minister Alexis Tsipras as well as other officials. He is… – Continue reading
Hong Kong’s Government should use greater-than-expected revenue receipts to implement measures to enhance the city’s international competitiveness in the 2015/16 Budget, according to a KPMG survey of senior Hong Kong-based business executives. It is foreseen that the Government will be in a position of increased fiscal strength at the end… – Continue reading
