Category: Statutory

Cayman tops ranking of money hideouts

Cayman is now the top enabler of financial secrecy in the world, according to the findings from the Tax Justice Network’s Financial Secrecy Index 2020. In second and third place respectively, were the United States and Switzerland. The Tax Justice Network has called on policymakers to prioritise sanctions against Cayman… – Continue reading

Canada: Treaty Shopping: MIL, MLI And ALTA Things In Between

On February 12, the Federal Court of Appeal (FCA) released its decision in The Queen v. Alta Energy Luxembourg S.a.r.l.1 (Alta Energy), a case that represents an attempt by the Canadian tax authority to relitigate the issue of whether Canada’s domestic general anti-avoidance rule (GAAR) can apply to curtail so-called “treaty shopping”.2   ... - Continue reading

Sweden’s tax agency rejects Puma’s transfer pricing position, concludes risk borne elsewhere

The Swedish tax agency has adjusted the taxable income for the PUMA Group’s Swedish distributor, Puma Nordic AB, concluding that, for transfer pricing purposes, the Swedish distributor could not control the main risks in the Puma Group and therefore should not have carried the local market risks. The adjustment, made… – Continue reading

Countries launch review of country-by-country reporting framework for multinational groups

An OECD-led group of 137 countries that work together on multinational group tax issues has released a consultation document and has requested public feedback to assist in a planned review of country-by-country reporting. The countries, known as the “Inclusive Framework on BEPS,” also scheduled a public consultation on the topic for March 17.
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Dhaka, Prague sign deal to avoid double taxation

Bangladesh and the Czech Republic have signed a double taxation avoidance agreement (DTAA) in a bid to strengthen bilateral trade and investment ties between the two countries. National Board of Revenue (NBR) chairman Md Mosharraf Hossain Bhuiyan and Czech deputy prime minister and finance minister Alena Schillerova inked the agreement… – Continue reading