Category: Statutory

The Finnish Supreme Administrative Court confirms that the business model chosen by parties must be respected in transfer pricing context

The Finnish Supreme Administrative Court published on 13 September 2017 precedent 2017:145 that further clarifies the scope of application of the Finnish transfer pricing adjustment provision (Act on Assessment Procedure (“AAP”) Section 31). In its previous landmark precedent KHO 2014:119 the Supreme Administrative Court stated that the so-called re-characterization of...

Econ experts laud tax reform plan

MANILA, Philippines — The Foundation for Economic Freedom (FEF) has expressed support for the tax reform program being pushed by the Department of Finance, saying this will lead to better lives for Filipinos. “The comprehensive tax reform program lays a solid foundation for the government’s vision of inclusive growth, improved...

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...

Analysis: Romania seeks tighter control of multinationals’ financial data

The government is looking to implement EU Directives on tax avoidance, and is set to receive more financial information from multinational groups active in Romania. Tax experts suggest that large corporations might reassess their business models in order to meet the demands of the fiscal authorities in Romania and across...

Canadian Businesses Urge Gov’t To Scrap Tax Plans

Thirty-five Canadian business organizations have written to Finance Minister Bill Morneau to ask that he scrap proposals to crack down on the use of tax planning strategies by private corporations. The business groups have together formed the Coalition for Small Business Tax Fairness to oppose the Government’s proposals. Signatories of...

Malawi Releases 2018 Budget

Malawi’s recent budget included numerous tax changes and announced updates to the country’s transfer pricing rules. On the indirect tax front, the Budget, released in mid-August, introduced a 10 percent excise tax on television subscriptions and introduced a value added-tax exemption for dairy products, animal or vegetable fats and oils,...

Changes to tax laws in sight for MNCs as the authorities adopt BEPS

MULTINATIONAL corporations (MNCs) in Malaysia will soon be seeing more tax law changes coming their way as the authorities get down to tackling base erosion and profit shifting (BEPS). This follows efforts by the Organisation for Economic Co-operation and Development (OECD), approved by G20 leaders, to formulate a 15-step action...

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...

Multinational giants accused of shifting Australian revenue offshore

Four of the world’s largest companies have been under investigation by Australian tax authorities, amid new evidence from US executives about how Facebook, Google, Apple and Microsoft are shifting money to offshore tax havens. Appearing before a highly anticipated public hearing into corporate tax evasion, the executives endured questions about...

Corporate tax hike contradicts global trend

The government’s plan to impose more levies on large companies will undermine their competitiveness amid a rising global trend of tax reductions and further distort the country’s taxation structure, analysts say. A draft tax code revision unveiled early this month proposes raising the corporate tax rate for businesses with taxable...

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....

Pakistan Sees Leap In Taxpayer Numbers

Launching the taxpayer directory for the 2016 tax year, Pakistan’s Finance Minister, Ishaq Dar, revealed that government efforts to broaden the country’s taxpayer base have been successful. The number of registered taxpayers, he said, has increased by nearly 50 percent from four years ago, when the first “directory” was released....

Brazil Says Offshore Assets Amnesty Yielded Billions

Brazil’s Inland Revenue has announced that assets worth BRL4.6bn (USD1.46bn) have been declared by Brazilian taxpayers through its amnesty for undeclared overseas holdings. It said that the income tax and fines linked to these assets totalled BRL1.6bn. The figures cover the period between March 3 and July 31, 2017, when...

HONG KONG, SINGAPORE AND CHINA GET TOUGH ON TAX HAVENS

In an effort to create a ‘level playing field’, Asian economies are committing to new standards of transparency At the risk of losing some foreign investors, Asian jurisdictions are stepping up efforts to combat corporate tax avoidance to meet new global transparency standards. More than a dozen Asia-Pacific jurisdictions have...

ATO’s finance ruling puts companies the ‘red zone’

The Australian Tax Office is preparing to take several companies to court over abuse of thin capitalisation rules and will start a wave of audits of large multinationals with complex cross-border loans, as it continues to take a hardline approach in the wake of its win against Chevron. The ATO...

EU lawmakers pass new rules to tackle multinationals’ tax avoidance

The European Parliament on Tuesday passed a directive requiring big multinationals to report tax and financial data separately in all countries where they operate, a measure aimed at tackling tax avoidance and profit shifting to countries with lower taxes. The new rules are part of a wider overhaul of tax...

FIRS To Join Automatic Exchange Of Information To Reduce Tax Evasion

The Executive Chairman of the Federal Inland Revenue Service (FIRS), Mr Babatunde Fowler said the organisation plans to join the global forum on Automatic Exchange of Information (AEOI) to reduce tax evasion. Fowler disclosed this on Sunday in Lagos on the sideline of the just concluded workshop on Automatic Exchange...