Category: Revenue

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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GRI issues international corporate tax reporting standard

The Global Reporting Initiative has issued a new international tax reporting standard that aims to ensure multinational companies are much clearer about how much they pay in taxes, and where. While the standard has no legal force, it could influence the ongoing debate in the U.S. and abroad on how… – Continue reading

‘Who is buying Seattle?’: New report issues warnings on Seattle’s luxury housing boom

Seattle’s luxury housing boom will worsen inequality and affordability in the city, according to a new report, which calls for officials to require more transparency on who is actually buying luxury real estate in the area. The report — “Who is Buying Seattle? The Perils of the Luxury Real Estate… – Continue reading

Dutch government asks banks to give American expats more time to deal with FATCA

The Dutch government is urging banks to be accommodating towards American nationals who risk having their bank accounts closed because of US fiscal regulations as it calls on EU member states to campaign together for changes to American tax laws which are affecting thousands who have American nationality but no… – Continue reading

BIR padlocks main office, 2 branches of tax-dodging POGO service provider

The Bureau of Internal Revenue (BIR) padlocked simultaneously Wednesday the main office and two branches of one of the biggest Philippine Offshore Gaming Operator (POGO) service providers in the country for alleged failure to register and pay the corresponding deficiency taxes amounting to P2 billion. Shuttered were the headquarter of… – Continue reading

VAT on online purchase must if not paid by cos during sourcing: NBR

Value-added tax on online purchase of goods and services will be applicable if the e-commerce company concerned collects those from the original suppliers and manufacturers without paying VAT, according to the National Board of Revenue. ‘There will be no VAT on online purchase of any goods and services if the… – Continue reading

Nigeria: The FIRS Has Published Regulations On Common Reporting Standard

The Federal Inland Revenue Service (FIRS) has issued the Income Tax (Common Reporting Standard) Regulations, 2019 (CRS Regulations). This follows Nigeria's signing of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAC) and the Multilateral Competent Authority Agreement (MCAA) on the Automatic Exchange of Financial Account Information, signed by Nigeria on 17 August 2017. ... - Continue reading

HMRC collects record £191bn in income tax

The taxman is raking in record amounts in income tax as the latest figures reveal Britons paid an extra £11bn in 2018/19. Income tax receipts have soared to a record £191bn, according to figures published, a 6% increase from the previous year. Britons are paying almost 30% more income tax… – Continue reading

Canadians for Tax Fairness concerned about inaction on Panama Papers

It is estimated that the use of tax havens is costing federal and provincial governments at least $7.8 billion in lost tax revenue. Low and middle income Canadians are the ones paying for that missing $7.8 billion in tax revenue. Ottawa (11 Aug. 2016) — The leak of the Panama… – Continue reading

Gaming Companies Call for Reaching USA-Croatia Double Taxation Avoidance Deal

ZAGREB, August 21, 2019 – Computer gaming is the most propulsive segment of the IT industry worldwide, and this trend is present in Croatia, too, where local gaming companies export all their products, however the biggest challenge in doing business is the absence of a Croatia-USA double taxation avoidance agreement,… – Continue reading

Senate inquiry into foreign workers’ tax payments pushed

SEN. Sherwin Gatchalian has called on the Senate to hold an inquiry on the uncollected taxes from registered and unregistered foreign workers, especially those in the Philippine Offshore Gaming Operators (POGOs) industry. n calling for an investigation, Gatchalian stressed that taxes properly collected are essential since revenues enable the government… – Continue reading

US appeals court sides with Amazon in $1.5 billion transfer pricing dispute

A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary in exchange for Amazon’s transfer of intangible property should not include compensation for transferred residual business assets such as workforce in place, goodwill, and going concern value. ... - Continue reading

High Court confirms ATO can use information from data leaks

Today the High Court confirmed that the ATO may use information obtained from data leaks, even if leaked from a law firm. Second Commissioner Jeremy Hirschhorn said today’s decision in Glencore International v. Commissioner of Taxation means the ATO can continue to use the ‘Paradise Papers’ and other similar data… – Continue reading

Tax from non-doms falls by £2bn as wealthy flee the UK

The number of wealthy residents who pay no UK tax on their offshore accounts has fallen to its lowest level ever, Treasury figures reveal. Last year, there were 78,300 non-domiciled taxpayers, or “non-doms”, in the UK compared with 98,500 in 2016-17. And the £9.5bn they paid to the taxman in… – Continue reading

FBR collects Rs1bln in revenue from foreign fund transfers

KARACHI: The Federal Board of Revenue (FBR) collected one billion rupees in withholding tax revenue on funds transferred abroad through credit and debit cards in a year, official statistics showed. The government opened the avenue for revenue collection a year ago considering the growing trend of payment through plastic cards…. – Continue reading