Category: Tax Authority

The common reporting standard and charities: do you have filing requirements with HMRC?

The Common Reporting Standard (the CRS) is, like FACTA (the Foreign Account Tax Compliance Act), an information exchange regime aimed at realising international tax transparency. Exchange of information under CRS is achieved by requiring certain bodies including banks and other “Financial Institutions”, to collect data and report some of it...

Data leak reveals details of 70,000 offshore firms in Malta, German state minister claims

Malta denies claims A data leak has revealed information about 70,000 offshore companies in Malta, a German state minister claimed this morning. North Rhine-Westphalia finance minister Norbert Walter-Borjans said the data also included information about several German corporations and up to 2,000 German taxpayers. Tax authorities in the city of...

UK: The UK Company: A New Alternative For International Investors?

This article is the first of a series of articles that looks at 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. An essential feature of...

Voices UN seeks a broader transfer pricing role

Four of the most significant transnational organizations are working together to eliminate transfer pricing schemes and abuses. The four organizations—the International Monetary Fund, the Organization for Economic Co-operation and Development, the United Nations and the World Bank Group—are seeking to achieve global cooperation in tax matters. Transfer pricing is one...

‘Ball In Bahamas Court’ Over Tax Exchange Pledges

“The ball is in the Bahamas’ court” to meet its automatic tax information exchange commitments, a senior industry executive yesterday saying there is “no alarm” about this nation having to alter its approach. #Tanya McCartney, the Bahamas Financial Services Board’s (BFSB) chief executive, told Tribune Business that the private sector...

Russia introduces draft law on country-by-country reporting requirements: implications for multinationals

A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry...

Transfer Pricing Investigation in China: Understanding the Latest Adjustments

New transfer pricing regulations issued by the State Administration of Taxation (SAT), the Measures for Administration of Special Tax Investigation Adjustment and Mutual Agreement Procedures (“the Measures”), came into effect on May 1, 2017. The Measures consolidate China’s pre-existing regulations regarding self-adjustment and outbound payments with the new transfer pricing...

Deal that sends Canadian bank records to IRS is ‘illegal,’ lawyer tells U.S. committee

Witnesses call for repeal of Foreign Account Tax Compliance Act An agreement that has resulted in hundreds of thousands of Canadian banking records being sent to the U.S. Internal Revenue Service could violate the U.S. constitution, a congressional subcommittee heard Wednesday. Testifying before a subcommittee of the House Committee on...

Newcastle United and West Ham raided in HMRC tax fraud investigation

Newcastle managing director Lee Charnley released after HMRC investigation Offices at St James’ Park and club training ground raided by tax authorities The offices of Newcastle United and West Ham United were raided on Wednesday morning and Chelsea confirmed they were asked to provide information as part of a wide-ranging...

Early adoption of tax common reporting standard problematic

Many of the data submissions made by early adopters over the next two months under the new common reporting standard (CRS) are likely to be rejected and returned for correction and resubmission, adding to compliance costs, according to predictions from Sovos, a global tax compliance solution provider The UK is...

Tax residency certificate is vital for claiming relief under DTAA

Tax residency certificate is required from the resident country tax authorities to claim applicable relief under the DTAA What is the purpose of a tax residency certificate? —Srivats Typically, source of income lies where the services are performed, or where the asset, from which the income arises, is located. Residential...

Germany Provides Update On 10-Point Tax Evasion Plan

The German Ministry of Finance has published a progress report on its 10-point plan to combat tax evasion, which was first announced in the wake of last year’s Panama Papers leak. The plan, launched on April 12, 2016, outlines the measures that Germany wants to put in place at domestic...

Cyprus: Abolition Of Profit Margins On Intra Group Loans – Upcoming Transfer Pricing Legislation – Transfer Pricing Studies Requirement

As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length...

Tax evasion of more than Rs 1.37 lakh crore detected in last three years

The Revenue Department on Friday said it has detected evasion of more than Rs 1.37 lakh crore in both direct and indirect taxes and identified over 1,000 shell companies which indulged in bogus transactions worth Rs 13,300 crore in the last three financial years. Warning tax evaders, it said the...

China’s New Transfer Pricing Rules Keep Arm’s-Length Approach

China’s new transfer pricing rules, effective May 1, endorse the continued use of the arm’s-length standard—the internationally agreed bedrock for pricing transactions within multinational enterprises. The new guidance, Bulletin 6, augurs well for resolving tax disputes between China’s State Administration of Taxation and the U.S. Internal Revenue Service over the...

HMRC to visit football clubs to review ‘image rights’ and other tax compliance

Dedicated technical experts from the UK’s HM Revenue & Customs (HMRC) will visit all English Premier League, Championship and Scottish Premier League clubs over a three year period and review all compliance risks including payments to players, the government has said. The statement was made in Treasury Minutes containing the...

Hong Kong signs agreements with Portugal and South Africa on automatic exchange of financial account information in tax matters

Hong Kong has signed agreements with Portugal and South Africa for conducting automatic exchange of financial account information in tax matters (AEOI), a Government spokesman said today (April 3). “We have been seeking to expand Hong Kong’s AEOI network with our tax treaty partners. The signing of agreements with Portugal...

HMRC launches Making Tax Digital pilot

HMRC has launched its Making Tax Digital for business pilot to test out its new reporting system, with a year to go before businesses with turnovers above the VAT threshold are required to switch to digital records and provide quarterly summary updates from April 2019 This month HMRC says it...

OECD recommends introduction of US-style deferred prosecution agreements in Scotland

ANALYSIS: US-style deferred prosecution agreements (DPAs) should be introduced in Scotland to deal with corporate offending, according to a recent report by the global Organisation for Economic Cooperation and Development (OECD). Foreign bribery should attract significant penalties, and Scotland’s civil settlement regime is potentially too lenient, according to the report,...

New Chinese tax rule to take aim at multinationals’ profit shifting

Move shows that Beijing is joining the global move against diversion of profits to low-tax jurisdictions Beijing on Saturday posted a new rule on scenarios that could trigger tax-avoidance investigations of multinationals, under¬lining its commitment to a global move to combat profit shifting. The new rule, posted on the website...

New Zealand Seeks Input On Automatic Tax Information Exchange

New Zealand has asked taxpayers for input on countries that lack the safeguards to ensure information automatically exchanged under the Common Reporting Standard (CRS) remains confidential. To comply with the new international tax information exchange standard developed by the OECD, the CRS, New Zealand must publish a list of jurisdictions...

Germany: Legislative proposal in reaction to Panama Papers

As a reaction to the so-called “Panama Papers” the German legislator proposed, on 30 December 2016, a draft bill to combat tax avoidance (so-called Steuerumgehungsbekämpfungsgesetz – StUmgBG). The aim of the draft bill is to enhance the German tax authorities’ means to determine and reveal EU-foreign domicile company structures which...

Countries ‘losing £400bn in taxes a year to profit shifting’

Governments around the world are losing as much as half a trillion US dollars (£400 billion) a year in tax revenue due to so-called “profit shifting” by multinational companies, according to research. The research published by the Tax Justice Network found that poorer countries were hardest-hit by the practice, which...