Category: Legislation

CbCR obligations for Italian entity members of US groups

Concerns have arisen over a temporary misalignment between the US country-by-country reporting regime and Italian legislation. Antonella Della Rovere and Federico Vincenti of Valente Associati GEB Partners explain. An agreement for the automatic exchange of country-by-country reports (CbCR) between Italy and the US (Agreement) came into effect on September 27...

EU Approves Rules to Fix 900 Cross-Border Double-Tax Disputes

European Union finance ministers gave formal approval to legislation designed to dramatically reduce the 900-plus unresolved company cross-border double taxation disputes. The Oct. 10 approval for the EU Double Taxation Dispute Resolution Directivecomes amid skepticism from tax professionals that it has the resources to be effective. It includes mandatory binding...

Ireland Seeks Comment on International Tax Strategy Plans

The Irish government is inviting businesses and practitioners to provide feedback on its plans to update its international tax strategy, including how Ireland should incorporate the OECD’s transfer pricing guidelines into national law and implement the European Union’s anti-tax avoidance rules. The consultation, which runs until the end of January...

OECD releases guidance to ensure BEPS country-by-country reports are used appropriately.

Canada has implemented the country-by-country reporting requirement for large multinational enterprises (MNEs) contained in the 2015 Final Report on Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan.  Canada’s legislation is found in s. 233.8 of the Income Tax Act (Canada), and is supported by the...

Panama probe: First prosecutions are taken to court for off-shore tax evasion

While at the beginning of the year (The Indian Express, March 16, 2017) the number of requests sent by India stood at 283 cases, it has now crossed 300. And while the number of replies received from among these 13 jurisdictions stood at 165, that figure has now crossed 240....

Court Rules In Favor Of Taxpayer In Canadian TP Audit Case

The Federal Court of Canada has ruled that the Canadian Revenue Agency may not conduct further in-person interviews with representatives from a multinational corporation concerning its transfer pricing affairs, having already discussed earlier tax years. Cameco Corporation declined to produce approximately 25 personnel for oral interviews in relation to an...

Australia: Proposed changes to CGT main residence exemption for foreign residents

The Treasurer has recently released exposure draft legislation (Treasury Laws Amendment (Housing Tax Integrity) Bill 2017) in relation to removal of the CGT main residence exemption for foreign residents. The changes are part of the Commonwealth Government’s ‘housing affordability’ reforms announced in the 2017-18 Budget. This will affect both Australian...

Big corporates seek lower tax rate

Some of New Zealand’s largest companies are calling on any future government to lower the corporate tax rate, which is becoming high compared to other countries, and a “New Zealand first” approach to policing cross-border finance arrangements that under-tax revenue in other countries. Published jointly by peak business lobby Business...

UK: The UK Company: A Tax-Efficient Business Vehicle For International Investors

This article is the third of a series of articles that examines tax aspects of the UK company which make it an attractive international business company, or “IBC”. This generic label, and its acronym, are normally associated with the BVI company, and its international competitors in other offshore financial centres....

Tech-based tax services gain pace to ensure businesses comply with global digital transparency standards

Global consultancy EY among firms now offering advanced services that redefine how companies face new developments in tax, audit and compliance Rigid new global initiatives to increase transparency of business data are giving rise to more advanced professional tax services, which employ innovative tools that include cloud computing, financial technology...

Worldwide: Italy And Greece Among Most Complex Places In The World For Accounting And Tax Compliance

Italy is the most complex jurisdiction in Europe and comes in first place globally for ‘tax’ complexity, while Greece is most complex in the world for ‘compliance.’ Italy and Greece are among the five most complex jurisdictions in the world for Accounting and Tax compliance, according to TMF Group’s inaugural...

EU Takes Legal Action Against Portugal, Two Others on Tax Deals

The European Commission launched legal proceedings against Portugal, Bulgaria, and Cyprus for not adopting, in their national laws, European Union legislation requiring all EU countries to exchange tax rulings granted to multilateral companies. The legislation was adopted in the wake of the 2014 LuxLeaks scandal that revealed more than 100...

Germany’s Schaeuble Defends Resistance to EU Public Tax Reporting

German Finance Minister Wolfgang Schaeuble defended his opposition to pending European Union legislation that would force large multinational companies to publicly disclose, on a country-by-country basis, their taxes paid and profits. Schauble, who testified before the EU Parliament’s Panama Papers investigative committee July 11, said public reporting of companies’ tax...

Cyprus: Saying Goodbye To Back To Back Loans And Welcoming Transfer Pricing Regulations

A. Introduction In February 2017 Cyprus Tax Department has announced that the current practice regarding profit margins between related Company loans will be abolished by the 30th June 2017. The announcement indicates that the minimum acceptable margins will apply up to 30th June 2017, and as from 1st July 2017...

TAJ Reports Perfect Record For FATCA Filings

Tax Administration Jamaica (TAJ) reported on Tuesday that local financial institutions required to report under the Foreign Account Tax Compliance Act (FATCA) are now 100 per cent compliant. FATCA is United States legislation designed to target US taxpayers holding accounts and assets outside that country and are non-compliant with US...

Tax avoidance crackdown will have ‘chilling’ effect on recruiters

A Europe-wide crackdown on tax avoidance schemes is set to have a “chilling” effect on recruiters and intermediaries marketing such schemes. The Guardian reported this week that the European Commission will publish proposals tomorrow to force financial intermediaries to automatically disclose any new cross-border tax schemes offered to clients. According...