Category: Revenue

New transfer pricing requirements in Latin America under BEPS

Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and Peru have included in their local legislation new documentation requirements that follow a three-tiered approach: country-by-country (CbC) report, master file,… – Continue reading

Tax Topics: Border-Adjustments And Tax Avoidance

The new administration and Congress have signaled their intention to undertake fundamental tax reform in the coming months. Lawmakers will need to weigh the costs and benefits of numerous policy trade-offs as they undertake this effort. Among the most visible debates already underway concerns “border adjustability,” or moving the U.S…. – Continue reading

Canada: Report On The Voluntary Disclosures Program (VDP) – Canadian Tax Consultant Analysis

The Offshore Compliance Advisory Committee issued a report in December 2016 to the Canada Revenue Agency about the Voluntary Disclosures Program (VDP or tax amnesty). If a taxpayer submits a successful income tax or GST/HST voluntary disclosure program application then generally criminal income tax prosecution and civil tax penalties under… – Continue reading

U.S. tax reform plan “not likely” to badly impact Canada: Expert

WASHINGTON — An American tax authority who helped champion a reform now being considered by the U.S. Congress says Canada would not be among the countries hardest hit by the introduction of so-called border adjustments. Alan Auerbach is among the leading proponents of the push to restructure corporate taxes so… – Continue reading

Tackling aggressive tax planning

THERE was a time when a tax professional would confidently tell you that tax avoidance would not get you in trouble. You might be bending the rules a little to minimise your tax liability, but as long as you followed the letter of the law, you would be fine. On… – Continue reading

Plans for Australia to adopt a ‘Google tax’ welcomed by advocacy group

Coalition’s proposed diverted profits tax could capture billions in revenue from multinationals using profit-shifting practices, says Tax Justice Network One of the biggest critics of multinational tax avoidance has welcomed the Coalition’s proposed “Google tax”, saying a similar tax in the UK looks likely to increase corporate tax payments by… – Continue reading

Pakistan has introduced another amnesty scheme for tax evaders – but why?

This, like previous initiatives, seems nothing more than a thinly veiled revenue measure. A new amnesty scheme is being considered to allow those who hold wealth abroad to bring it back into the country without facing a penalty other than paying a nominal amount of tax on the value of… – Continue reading

Australia Consults On Failure To Disclose Penalties For MNEs

The Australian Treasury is consulting on plans to increase administrative penalties for multinationals that fail to adhere to tax disclosure obligations. The new rules will apply to companies with global revenue of AUD1bn (USD749.7m) or more. From July 1, 2017, penalties relating to the lodgment of tax documents to the… – Continue reading

Worldwide: The OECD’s Conquest Of Domestic Tax Codes: Understanding The Costs And Consequences Of The BEPS Project

Authored by IFC Media Recent global events from the release of the Panama Papers to a series of high-profile inversions have given international tax regulators both rhetorical ammunition and public support to execute a global crackdown on multinational tax planning. The goal is to increase total taxes paid by global… – Continue reading

Google & Indonesia Fail to Reach Tax Agreement in 2016

US multinational technology company Google failed to reach a tax settlement with Indonesia’s Tax Office in 2016 and therefore directors of Google Indonesia could risk a prison visit. In September 2016 Muhammad Hanif, Head of the Tax Office’s Special Cases Department, said Google could face claims for five years of… – Continue reading

Singapore Goes The Mauritius Route, Loses Right To Tax Equity Capital Gains Arising In India

Starting April 1, 2017, India will have the right to tax capital gains arising on Indian equity shares sold by a Singapore resident. The governments of India and Singapore have amended the double taxation avoidance treaty between the two countries, in line with the changes India recently made to a… – Continue reading

Proponents of online sales tax hope to deliver revenue to N.M.

Cyberspace may not be a tax haven for New Mexico shoppers much longer. As bipartisan support grows among state lawmakers for tax collections on internet sales to bring in more revenue and help level the playing field for local businesses, major internet companies are becoming increasingly willing to comply and… – Continue reading

South African Tax Bills Approved By Parliament

South Africa’s Ministry of Finance has published the 2016 Taxation Laws Amendment Bill (TLAB), which has received parliamentary approval and gives effect to the tax changes announced in the Budget in February this year, together with legislation confirming the final details of the Special Voluntary Disclosure Program (SVDP). With changes… – Continue reading

Apple, Netflix, MS and IBM may have to pay `google tax’

The `Google tax’ could soon ensnare the likes of IBM, Microsoft, Amazon Web Services, Apple and Netflix, which provide online services in India. Cloud computing companies and content providers with customers in the country may be needed to pay equalisation levy on their revenue from the next financial year as… – Continue reading

Rate Competition Is New International Tax Planning Reality

Lower corporate tax rates around the world are expected to play an important part in multinational companies’ tax planning in 2017, with a rate as low as 15 percent on the table in the U.S. and countries such as the U.K. planning to maintain or lower their current rates. A… – Continue reading

‘We do not avoid tax’ insists Facebook

Facebook Ireland yesterday declared “we do not avoid tax” as revenues and pre-tax profits soared to record levels. New accounts show that Facebook Ireland Ltd’s corporate tax bill of €16.53m for 2015 represented only a tiny fraction of its record revenues of €7.89bn. The 63pc – €3bn – increase in… – Continue reading

Showdown between ATO and big business looms as list of company tax paid is revealed

A showdown between the Australian Taxation Office and the nation’s largest companies including Chevron, Crown and BHP Billiton is looming as the tax man hits seven large companies with tax bills amounting to $2 billion. On Friday, the ATO released its corporate tax transparency report for 2014-15, which includes limited… – Continue reading

Final opportunity to disclose offshore assets before 1 May 2017 introduced by Finance Bill 2016

1. Why was a new offshore provision introduced by this year’s Finance Bill? Following revelations in the “Panama Papers” of major worldwide tax evasion in April 2016 (which included certain Irish Resident account holders), the Minister for Finance announced on budget day, 12 October 2016 that this year’s Finance Bill… – Continue reading

Bermuda is world’s worst corporate tax haven, says Oxfam

Four UK territories in list ‘undermine Britain’s efforts to be responsible member of the international community’ Bermuda is the world’s worst corporate tax haven, according to a list by Oxfam, which includes three other UK territories among those it names and shames. The charity’s list of the “world’s worst” 15… – Continue reading

McDonald’s to scrap Luxembourg tax structure

Fast-food chain’s reorganisation means £800m from restaurants in Europe will flow through the UK instead McDonald’s is to scrap its controversial Luxembourg tax structure in a corporate shakeup that means $1bn (£800m) of income from fast-food restaurants across Europe will flow through the UK instead. The move comes 12 months… – Continue reading

German Tax Authorities Slam Amazon as Haven for Tax Dodgers

Amazon effectively offers a safe haven for businesses that want to avoid sales tax, German revenue officials told Handelsblatt on condition of anonymity. In June, authorities raided eight Amazon locations across Germany as part of an investigation into a Chinese trader who had sold goods through the online marketplace without… – Continue reading

Is Ireland making unfair tax deals with developing countries?

A new report says little has changed after a number of global tax scandals… Ireland is entering unfair tax deals with developing countries according to a new report on ‘sweetheart deals’ in the EU. Of the 18 countries in the study, Ireland is found to have on average “introduced the… – Continue reading

HUNGARY COULD BE A CORPORATE PROFIT TAX HAVEN IN THE EUROPEAN UNION

The new 9 percent flat corporate profit tax – to be introduced 1st of January 2017 – will put Hungary in a very good position in the international race for investments as Hungary will offer even better conditions than Ireland and Cyprus, which are both often regarded as the European… – Continue reading

Switzerland eyes AEOI with 21 countries

Switzerland, which has been working to end its years-long practice of banking secrecy, on Thursday said it aimed to dramatically increase the number of countries it cooperates with toward international fiscal transparency. The Swiss government said in a statement that it wanted to extend the automatic exchange of information (AEOI)… – Continue reading

‘Revenue will look for you – and it will find you’

Taxpayers with offshore assets urged to get affairs in order before May clampdown Taxpayers with offshore assets ranging from foreign properties to deposit accounts or structured investments are being urged to get their affairs in order ahead of a May clampdown by the Revenue Commissioners – even if they believe… – Continue reading

Kenya to lend its tax expertise to Botswana after historic deal

The Kenya Revenue Authority has signed an international memorandum of understanding on tax collaboration with Botswana, to provide administration assistance from next year. Tax officials from Kenya and Botswana on Thursday agreed to the assistance project that marks the first South-South cooperation pact under the Tax Inspectors Without Borders programme… – Continue reading

Implementation of Common Reporting Standard in Hong Kong – Implications for Family Trust with a Private Trust Company as Trustee

The Organization for Economic Co-operation and Development (OECD) issued the Standard for Automatic Exchange of Financial Information in Tax Matters (Standard for AEOI) in July 2014, which aims to prevent offshore tax evasion and maintain the integrity of tax systems. Over 100 jurisdictions have committed to comply with the Standard… – Continue reading

Google, Facebook Targeted by Indonesia in Push for More Tax

Indonesia is widening its tax net to target global technology giants like Google and Facebook Inc., a strategy that’s raising red flags for fear it may deter foreign investment. Finance Minister Sri Mulyani Indrawati is seeking to squeeze more revenue out of an economy that’s been hit by weak commodity… – Continue reading

OFFSHORE TAX HAVENS COST SMALL BUSINESSES ON AVERAGE $5,128 A YEAR

Small businesses in the U.S. have to shoulder, on average, an extra $5,128 in taxes to make up for the revenue lost due to the abuse of offshore tax havens by multinational corporations, according to a new report by U.S. Public Interest Research Group Education Fund. As a new administration… – Continue reading

Country’s richest hit with €36m tax bill

A major Revenue crackdown on tax-avoidance schemes used by Ireland’s richest people has clawed back more than €36m for the taxpayer in the past year. The tax-avoidance team at Revenue’s large cases division has agreed settlements with a number of high-wealth individuals – defined as those with net assets greater… – Continue reading

MEPs back automatic exchange of bank data

Tax authorities across Europe will be able to automatically share information about bank account holders, according to a Council position approved by the European Parliament on November 22. It was passed by 590 votes to 32 votes, with 64 abstentions. According to a European Parliament press release, the new rules… – Continue reading

Microsoft agrees to more transparency on taxes in Australia

The Australian government is one of the most aggressive in highlighting the issue of multinational corporations avoiding taxes through extensive use of tax havens. Microsoft’s Australian subsidiary will start disclosing the amount of tax it pays in Australia, opting in to a government-transparency program aimed at shedding light on the… – Continue reading

SNP MP warns that tax office cuts will lead to an increase in the gap between the rich and poor

TAX office closures will lead to a surge in the gap between rich and the poor and an increase in tax avoidance as well as people not being paid the minimum wage, the UK Government has been warned. Under controversial HMRC plans 18 Scottish offices, including major centres in Dundee,… – Continue reading

Dispute resolution under the Nigerian transfer pricing regime

Background The Federal Inland Revenue Service [FIRS] has begun Transfer Pricing [TP] audits and has been requesting TP documentation and other documents from taxpayers relating to their related party transactions. These actions are in line with its powers under the Income Tax (Transfer Pricing) Regulations No. 1 of 2012 [Regulations]… – 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

Dumping Obama’s faux foreign tax legislation should be high on Trump’s to-do list

President-elect Donald J. Trump has stated that among his top priorities will be revocation of President Barack Obama’s misguided executive orders. Among the first such items to get the ax should be a series of legally infirm international agreements to implement a monstrosity unfamiliar to most Americans, called the Foreign… – Continue reading

Anti-terrorism tactics should be applied to tax havens, report says

The same aggressive and uncompromising international effort used to combat terrorism must be employed to eliminate tax havens, says Nobel Prize-winning economist Joseph Stiglitz in a report being released Tuesday. In a copy of the report, obtained by the International Consortium of Investigative Journalists and shared with the Star, Stiglitz… – Continue reading

CRA investigating 85 Canadians for tax evasion tied to Panama Papers

Eighty-five Canadians identified in the Panama Papers leak are now being investigated for tax evasion, the Canada Revenue Agency has revealed. Details of Canada’s enforcement effort were provided to the Star the same week the U.K., which is a major hub of the offshore finance world, said it has launched… – Continue reading

The coming abolition of cash

The Indian Government’s dramatic cancellation of large banknotes on the same day as the US election last week looks like the drastic solution to a very Indian problem with tax avoidance and the black economy, but it might turn out to be a harbinger of things to come everywhere. In… – Continue reading

FBR to file FIRs against owners of offshore companies

ISLAMABAD: The Federal Board of Revenue (FBR) is making preparation for registration of FIRs against those selected individuals who owned offshore companies and were named in Panama/Bahamas Leaks but failed to comply against the sent-out tax notices within the stipulated timeframe. The FBR found 114 cases whereby individuals were non-compliant… – Continue reading

Govt looks to resolve 100 transfer pricing agreements by March next year

MUMBAI: With a hope of improving India’s image on ease of doing business, the government has increased the pace of resolving transfer pricing issues and is looking to sign around 100 advance pricing agreements by the end of March 2017, people in the know said. Central Board of Direct Taxes… – Continue reading

EU To Crack Down On Promotion Of Aggressive Tax Planning

The European Commission has launched a public consultation on how best to deter promoters of aggressive tax planning schemes. The Commission said it is particularly interested in gathering views on how a mandatory disclosure scheme for tax advisers could be put in place. If implemented, this would require intermediaries to… – Continue reading

Ukraine’s Cabinet of Ministers endorses draft agreement on FATCA with US

Ukraine’s Cabinet of Ministers has approved a draft agreement with the U.S. government to improve the implementation of tax rules and apply the provisions of the U.S. foreign account tax compliance act (FATCA). The decision is outlined in government resolution No. 821-r dated November 9, 2016 posted on the government’s… – Continue reading

Hong Kong Pushes For DTA, Info Exchange With Australia

In Canberra, Hong Kong’s Secretary for Financial Services and the Treasury, K C Chan, expressed his wish to quickly start negotiations on a comprehensive double taxation agreement (CDTA) with Australia. During his meetings with Australia’s Treasurer, Scott Morrison, and the Minister for Revenue and Financial Services, Kelly O’Dwyer, Chan pointed… – Continue reading

Australian Practitioners Urge Zero Withholding for Pooled Funds

Practitioners in the managed funds industry are calling for a zero-rate for withholding tax in Australia amid the government’s proposals for new tax concessions to boost it, saying the proposed measures don’t go far enough. The government released a consultation paper Nov. 3 on non-resident withholding taxes for pooled funds—or… – Continue reading

IRD delayed multinational tax crackdown

New Zealand has delayed cracking down on multinational tax avoidance due to private sector concerns over timing and concerns about “scaring away” foreign investment, the Inland Revenue Department says. Wide-ranging reforms to corporate tax rules proposed by the Organisation for Economic Cooperation and Development (OECD), known as the base erosion… – Continue reading