Spain to scrutinize taxpayers’ transfer pricing positions
Spain focuses on transfer pricing. ... - Continue reading
Category: Tax Arrangement
Disclosure of cross-border arrangements
HMRC has recently been consulting on how the UK will implement new EU disclosure rules contained in the latest Directive on Administrative Cooperation (DAC6). ... - Continue reading
New Zealand, Guernsey sign tax treaty protocol
The governments of New Zealand and Guernsey on September 18 signed protocol to their tax information exchange agreement, the New Zealand government has announced. ... - Continue reading
Colombia: Colombia Publishes Guidelines On Advance Pricing Agreements
Colombia's National Directorate of Taxes and Customs (DIAN) released detailed guidelines (the Guidelines) to clarify the procedure for Advanced Transfer Pricing Agreements (APAs) requests in order to ensure certainty between the parties regarding their transfer pricing arrangements. ... - Continue reading
European Union: EU Directive On Administrative Cooperation In Field Of Taxation Amended
The European Union has added further impetus to its objective of providing greater transparency with regard to harmful tax practices through an amendment to EU Directive 2011/16/EU. ... - Continue reading
IRS To Probe Deeper Into Cost-Sharing Arrangements
Transfer pricing positions to be reviewed by IRS ... - Continue reading
Delving into Hong Kong’s New Transfer Pricing Landscape
On July 4, 2018, Hong Kong’s Inland Revenue Department passed the country’s final Inland Revenue (Amendment) (No. 6) Bill 2017, (the Amendment Bill). This Amendment Bill (which became law on July 13, 2018) specified the documentary requirements from a transfer pricing perspective and also introduced measures to address various recommendations… – Continue reading
HMRC targets accountants over tax evading clients
HMRC sent 1,414 requests to professional services firms demanding confidential information on clients suspected of tax evasion in the 12 months to 31 March 2018, according to law firm RPC. The production orders are issued by HMRC’s Criminal Investigation Directorate to force third parties, such as accountants, lawyers and other… – Continue reading
Steven Gerrard sues HSBC for £100m over tax schemes
Rangers manager Steven Gerrard is taking legal action against his wealth manager following a crack down on tax avoidance schemes. The former Liverpool captain is among hundreds of investors who have launched a £100m lawsuit against HSBC’s private banking division, claiming it defrauded them, The Times has reported. Composer Lord… – Continue reading
Panasonic to Move European Headquarters Out of UK as Brexit Concerns Grow
Several multi-national corporations have moved their European headquarters outside of the UK ahead of Brexit, and many others are expected to follow suit, especially as the likelihood of a no-deal Brexit rises further. Japanese tech giant Panasonic will be transferring its European HQ away from London to Amsterdam in October… – Continue reading
UK – GOVERNMENT PUBLISHES OFFICIAL GUIDANCE ON ENGAGING WITH UMBRELLA COMPANIES
The HMRC published an official guidance yesterday on engaging with umbrella companies in the UK. The guidance provides advice and spotlights umbrella companies that effectively operate tax avoidance schemes. “Most employment agencies and umbrella companies operate within the tax rules. However, some umbrella companies and agencies promote arrangements that claim… – Continue reading
Outrageous tax incentives harming local businesses – ECG Chairman
The current tax incentives arrangement for foreign investors looking to invest in key sectors of the economy ends up financing multinationals to the detriment of local businesses who continue to wobble under severe taxation, Marwan Ansah, Western Regional Chairman, Senior Staff Union of the Electricity Company of Ghana (ECG), has… – Continue reading
Inland Revenue (Amendment) (No. 6) Ordinance 2018 gazetted
Hong Kong (HKSAR) – The Inland Revenue (Amendment) (No. 6) Ordinance 2018, which primarily implements the minimum standards of the Base Erosion and Profit Shifting (BEPS) package promulgated by the Organisation for Economic Co-operation and Development (OECD) and codifies the transfer pricing principles into the Inland Revenue Ordinance (Cap. 112)… – Continue reading
‘Double taxation arrangement’ renegotiated
Document to be presented to Tynwald after summer recess The Isle of Man has agreed a renegotiated ‘double taxation arrangement’ with the UK. Howard Quayle met with Mel Stride MP yesterday, who is Financial Secretary to the Treasury and Paymaster General across, to sign the document which replaces the agreement… – Continue reading
Shell’s dubious tax arrangements
Shell avoids the dividend tax via a tax haven, which would have cost the Dutch treasury – and therefore the taxpayer – at least € 7 billion… The intervention of a ‘trust’ on channel island of Jersey seems to underline the dubious character of the ‘deal’. Pressing Rutte to exchange… – Continue reading
Australia Provides Update On International Tax Enforcement
In comments to the TPMinds International Conference in late March, Deputy Commissioner Mark Konza outlined the Australia Taxation Office’s priorities in the area of international tax enforcement, with an especial focus to be placed on the energy and resources sector and pharmaceutical industry. His comments, published by the ATO on… – Continue reading
Court classifies medical firm tax planning as evasion
Tax authorities reviewed a case in which a doctor worked at a limited partnership firm and was paid via a limited liability company. The court described the arrangements as tax evasion. Many professionals would prefer to pay taxes on capital income because the tax burden is lighter than on earned… – Continue reading
Malta Backs EU Crackdown On Aggressive Tax Planning
Malta has reiterated its commitment to fighting aggressive tax planning, joining other EU member states who have unanimously agreed to amend the EU’s tax information sharing law, the Directive on Administrative Cooperation. The amendments to the Directive, which were agreed last week by EU finance ministers, will require intermediaries, such… – Continue reading
Hong Kong and India enter into tax pact
Hong Kong (HKSAR) – The Financial Secretary, Mr Paul Chan, on behalf of the Government of the Hong Kong Special Administrative Region, signed in Hong Kong today (March 19) a comprehensive agreement for the avoidance of double taxation (CDTA) with the Ambassador of India to China, Mr Gautam Bambawale, signifying… – Continue reading
Dutch Cabinet Approves Anti-Evasion Measures
The Government of the Netherlands has announced a comprehensive package of tax anti-avoidance proposals designed to bring the jurisdiction’s rules into line with new European Union anti-avoidance laws and fulfill its obligations under the international BEPS agenda. The plans were detailed in a parliamentary paper sent by State Secretary for… – Continue reading
Barbados Agrees To Phase Out Harmful Tax Regimes
Two Barbados preferential tax regimes have been labelled “potentially harmful” in additional guidance released by the OECD in connection with its base erosion and profit shifting (BEPS) project. The guidance singles out Barbados’s international financial services regime and its credit for foreign currency earnings/credit for overseas projects or services regime…. – Continue reading
Jersey, Guernsey and Isle of Man join commitment to tackle tax evasion
The commitment comes amid ongoing controversy over the use of complex tax arrangements following the Paradise Papers leak. The islands of Jersey, Guernsey and the Isle of Man have signed up to a joint commitment with the British and Irish governments to tackle tax evasion and abusive tax avoidance. The… – Continue reading
Apple, Ireland, the EU and a 13 bn euros tax bill; cold justice in the offing
Ireland is set to taste cold justice at the hands of the EU which has taken it to the European Court of Justice (ECJ) for failing to collect a year-old tax bill of a whopping 13 billion euros from American tech giant Apple. To be sure, the EU competition commission… – Continue reading
EU eyes corporate rules shake-up with law on seat transfer
The European Commission is preparing a new directive on the cross-border transfer of company headquarters, a move that could have far-reaching implications for other areas of corporate governance, including tax planning and cross-border mergers, EURACTIV has learned. With Brexit on the horizon, UK companies are busy weighing their options for… – Continue reading
Hong Kong to examine tax concessions to attract global funds, Financial Secretary says
Financial Secretary Paul Chan Mo-po said tax incentives would help Hong Kong compete with other fund management centres The government will examine the existing tax concessions applicable to the fund industry to make Hong Kong into a diversified and competitive international fund management centre against its global counterparts, said the… – Continue reading
Slow UK aid for hurricane-hit islands linked to tax haven ties
Anguilla’s ex-attorney general says UK government may fear exposing its role in Caribbean territories’ tax arrangements Aid offered by the British government to its hurricane-battered territories in the Caribbean has been dismissed as “derisory” by a former attorney general of one of the worst-hit islands. Rupert Jones, who completed a… – Continue reading
HMRC invokes GAAR to clamp down on gold bullion tax avoidance schemes
Paying employees in gold bullions to avoid tax will not be permitted under the first use of the general anti-abuse rule (GAAR). The GAAR advisory panel stated that the use of gold as payments for employees is “abnormal and contrived” and “not a reasonable course of action”. “We can see… – Continue reading
Airbnb paid French tax man just €93,000
France is Airbnb’s second largest market and yet in 2016, the internet giant paid the country just €92,944 in taxes – equivalent to the amount paid by small and medium-sized enterprises (SMEs). Second only to the US as Airbnb’s biggest market and with Paris its top city for listings, during… – Continue reading
OECD Seeks Taxpayer Input On BEPS Action 14 Peer Reviews
The OECD is seeking taxpayers’ input on the mutual agreement procedure (MAP) frameworks in place in the third batch of countries that will now be peer reviewed under Action 14 of the OECD’s base erosion and profit shifting Action Plan: the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, and… – Continue reading
Corporate giants hit with $2.2b Australia tax bill
Companies including Apple, Google and BHP Billiton were grilled at parliamentary hearings on their tax structures in 2015 SYDNEY: Australia on Thursday said it had slapped seven large multinationals with a multi-billion-dollar tax bill as it pursued global firms shifting profits offshore to minimise liabilities. The companies hit with the… – Continue reading
Investors face higher tax bills on stapled securities
The federal government is considering doubling the tax rate applied to more than $199 billion worth of so-called stapled structures, in a move that experts say could scare off foreign investors. Separate securities, such as a share in a company and a unit in a trust, can be stapled together… – Continue reading
Switzerland Gets To Work On New Tax Proposals
The Swiss Federal Department of Finance has said that it is forging ahead with work on a new corporate tax proposal, named “tax proposal 17” (TP17). A steering committee held its first meeting on March 2. It is led by Federal Councillor Ueli Maurer and comprises members from the government… – Continue reading
Switzerland Rejects Corporate Tax Reform
Proposed changes to Switzerland’s corporate tax framework have been rejected in a referendum. Provisional results show that the Corporate Tax Reform III (CTR III) package was opposed by just over 59 percent of voters in the February 12 referendum. CTR III would have abolished corporate tax arrangements that the Swiss… – Continue reading
UK-Swiss Terminate Savings Tax Deal For Automatic Info Exchange
The UK and Switzerland have terminated tax arrangements under the Savings Tax Directive and will instead share information in tax matters automatically under the Common Reporting Standard. The UK Government said, under the switch to the OECD’s Common Reporting Standard, UK taxpayers will no longer be able to pay a… – Continue reading
Government planning action to target multinationals over tax
The Government is planning unilateral action to crack down on tax dodging by multinational companies, including changing the law, amid growing concern about fairness. Revenue Minister Michael Woodhouse said proposals outlined in a cabinet discussion document tabled last month would see Inland Revenue properly armed to tackle the problem and… – Continue reading
Ireland Rejects Oxfam’s Tax Haven Claims
Ireland’s Ministry of Finance, the EU and several other governments have emphatically rejected claims by Oxfam International that the countries are tax havens, with Ireland insisting its corporate tax laws are “fully compliant” with international best practices when it comes to transparency and information exchange. The Irish government said the… – Continue reading
Putting an end to corporate tax controversy
Controversy over giant corporations paying dwarfed tax bills has put finance chiefs in the media and public spotlight When giant companies with devilishly complex tax arrangements are accused of unethical behaviour, the stock response is “we act within the rules”. If the public and politicians don’t like it, the argument… – Continue reading
Australia’s Google Tax may be the second in the world but it’s too early to tell if it’s the ‘toughest’
When introducing the draft legislation for the Diverted Profits or so-called “Google Tax”, Federal Treasurer Scott Morrison claimed it would: …reinforce Australia’s position as having amongst the toughest laws in the world to combat corporate tax avoidance. Australia is the second country to introduce this type of tax, after the… – Continue reading
Tens of millions of dollars of revenue lost through dodgy trust structures
Just a handful of dodgy tax structures being used by Australians cost tens of millions of dollars in lost revenue, according to the Australian Taxation Office. That could mean many millions more are missing, and is why the ATO is cracking down on people misusing trusts. The agency has long… – Continue reading
Labour and unions demand action on temp agencies’ tax avoidance
Opposition vows to shut down scheme that uses ‘contrived’ financial arrangements to slash national insurance bills Labour and trade unions have called on the government to take action after a Guardian investigation found that an aggressive tax avoidance scheme used by temporary recruitment agencies is depriving the taxpayer of “hundreds… – Continue reading
Multinationals still able to use ‘double Irish’ tax arrangement after 2020
Multinational companies will still be able to use the controversial “double Irish” tax arrangement after the final end date of 2020, Sinn Féin MEP Matt Carthy has said. A number of tax experts have confirmed this is the case, though they have disputed whether the terms of which they will… – Continue reading
McDonald’s UK pays £123m in royalties to Luxembourg
The British arm of McDonald’s paid £123m for “franchise rights” last year, as part of a controversial structure that is under investigation for enabling unfair tax avoidance. The European Commission launched a probe last year into whether Luxembourg’s tax arrangements for McDonald’s amounted to illegal state aid, as part of… – Continue reading
BHP Billiton has evaded taxes for more than a decade, says Wayne Swan
Former Labor treasurer Wayne Swan has accused one of Australia’s biggest companies of evading taxes for more than a decade, and for lying to the former Labor government during the height of the mining tax debate. Swan used parliamentary privilege on Wednesday to claim BHP Billiton had been “gaming the… – Continue reading
European Parliament Begins Panama Papers Probe Despite Tax Haven Splits
Members of the European Parliament, September 27, have begun their investigation into the Panama Papers scandal, which exposed the sheer extent of rich people and companies using offshore tax havens to reduce their tax liabilities in EU member states. However, the latest probe comes on the back of another investigation… – Continue reading
Democrats Introduce Corporate Tax Transparency Bill in Congress
House Democrats have introduced legislation that would require multinational corporations to disclose more information about the taxes they pay in other countries. The bill, known as the Corporate Transparency and Accountability Act, aims to shine more light on corporate tax avoidance strategies, requiring the disclosure of country-by-country and pre-tax profit… – Continue reading
Wales to switch to Land Transaction Tax
Wales is to replace stamp duty with a land transaction tax as it moves towards devolved tax collection. The new tax on land transactions will be introduced from April 2018 alongside measures to tackle devolved tax avoidance, the Welsh government said. Land transaction tax is paid on the purchase or… – Continue reading
EU countries eye potential share of Apple windfall
Potential slice of the Apple pie stems from Commission’s invitation to EU tax authorities. BRATISLAVA — The €13 billion clawback of unpaid taxes from U.S. tech giant Apple has piqued the interests of EU finance ministers, who have today asked the European Commission for more details on the potential share… – Continue reading
Obama warns G20 of risk of tax ‘race to the bottom’
The G20 summit in China has stressed the need for international tax cooperation to achieve ‘a globally fair and modern international tax system’, after US President Obama warned of the risks if countries ‘race to the bottom’ in tax policies At a press conference at the conclusion of the summit,… – Continue reading
Luxembourg may be focus of another Brussels tax inquiry
After state aid inquiries into Amazon and McDonald’s, EU looks again at Luxembourg The European Commission may open a fresh investigation into tax rulings offered by Luxembourg as early as this week, as EU competition commissioner Margrethe Vestager continues her clampdown against corporate tax avoidance. Luxembourg is already awaiting a… – Continue reading
Ireland risks being trampled in US/EU corporate tax fight
For the last three years, the international debate on tax policy was all about consensus. Led by the Organisation for Economic Co-operation and Development, countries across the globe agreed that aggressive tax planning by multinational corporations which pushed profits into low-tax countries – or indeed took profits outside the charge… – Continue reading
