Category: Activity

Covid-19 / Employment / France / Non-Domiciled / Permanent establishment / Residence / Tax Laws / United Kingdom

Temporary Work Locations in a Permanent Establishment World

Published by: Tax Foundation - April 7, 2020

The COVID-19 crisis has caused quite some chaos in the world right now. As we find ourselves homebound, there are also employees trapped in foreign countries to them. In such a case, what happens to the link between tax presence and tax residency? Here is brief discussion. ... - Continue reading

Base Erosion & Profit Shifting / Jurisdiction / Mutual Agreement Procedure / OECD

OECD issues MAP peer review reports for further eight jurisdictions

Posted On: March 5, 2020

The OECD on February 24 published stage 1 mutual agreement procedure (MAP) peer review reports of the following eight jurisdictions: Brunei Darussalam, Curaçao, Guernsey, Isle of Man, Jersey, Monaco, San Marino, and Serbia. The reports highlight how well these jurisdictions are implementing the base erosion and profit shifting (BEPS) Action… – Continue reading

Canada / Dividends / Infrastructure / Investments / Lease / Legislation / Profit Shifting / Revenue / Royalties / Tax Authority / Tax treaties / Treating Shopping / Treaty Abuse

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

Published by: Mondaq - February 19, 2020

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

Base Erosion & Profit Shifting / Double Taxation / India / Sri Lanka / Tax Evasion

Cabinet approves India-Sri Lanka Agreement amendment on double taxation, evasion

Posted On: February 12, 2020

New Delhi: The Union Cabinet, chaired by Prime Minister Narendra Modi, has approved the signing and ratification of the protocol amending the Agreement between India and Sri Lanka for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, according to a Press… – Continue reading

EU / Forms / OECD / Revenue / Sweden / Transfer pricing

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

Posted On: February 11, 2020

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

Banking / Business / Debt / Guaranty Trust Bank / Infrastructure / Legislation / Offshore / Offshore Investments / Offshore Trusts / Tax Laws

GTBank Urges FG to Introduce Structural Reforms

Posted On: February 10, 2020

The recurring inability of government to achieve its projected non-oil revenues over the years points to the need for urgent structural reforms, a report by Guaranty Trust Bank Plc (GTBank) has stated. The bank stated this in its 2020 macroeconomic and banking sector outlook, obtained yesterday. It stressed the need… – Continue reading

Framework / G20 / Lease / Multinationals / OECD / Permanent establishment / Revenue / Transfer pricing

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

Published by: MNE Tax - February 9, 2020

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.
... - Continue reading

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