In our last publication, we discussed the signing of the Ghana-Morocco Double Tax Agreement (“DTA”) and the provisions of the DTA in relation to the taxation of permanent establishments and business income. In the concluding part of the article, we will discuss the taxation of investment, employment and service incomes...
In order to tackle irregularities and unfair competition among e-commerce companies, Ankara is planning to form a special unit to track e-commerce activities and transactions in the country The Turkish government is planning to create a special unit of 200 people to track e-commerce activities in the country, Finance Minister...
Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country...
The OECD has taken issue with the Estonian Government’s plans to reduce the rate of tax on distributed dividends for established companies, warning that the measure could complicate the tax system and discriminate against small firms. Under recently enacted legislation, tax on distributed dividends will be reduced from 20 percent...
Ireland’s Minister for Finance (the “Minister”) welcomed the results of the independent review of Ireland’s corporation tax regime (the “Review”) issued on 12 September 2017: “I welcome the emphasis given in the Review to the importance of certainty, which is core to our corporate tax offering. Our 12.5% corporation tax...
Letters calling for the elimination of FATCA, among other tax issues, will be presented to the White House in about two weeks’ time. A global political organisation with affiliation to the Republican Party has recently launched a petition and letter writing campaign in protest of “citizenship-based” taxation – partly in...
…as tax dispute escalates Vodafone Ghana has filed a motion at the High Court of Justice, Commercial Division in Accra, against the Ghana Revenue Authority (GRA) disputing tax assessments of GH¢160 million, according to the Writ obtained by ghanabusinessnews.com. The GRA has asked Vodafone to pay 30 per cent of...
Some double tax treaties are being amended by a multilateral instrument Establishing how a particular treaty is affected can be a complicated process The UK intends to publish amended DTTs and this will help, but the MLI has added an additional layer of complexity 18 Sep 2017 Speed Read LEGAL...
Changes in international tax laws spurred by the OECD’s BEPS project pose challenges for finance chiefs, but also offer some opportunities. The OECD’s base erosion and profit shifting (BEPS) project, with an overall goal of reducing global loss of tax revenues due to double non-taxation, has created the need for...
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...
The CEO of the Swiss Bankers Association (SBA) has stressed that confidentiality, data security, and data protection requirements must be complied with when the automatic exchange of tax information gets underway. Claude-Alain Margelisch argued that there should also be a “number of security mechanisms in place that protect customers and...
Consumers’ complaints of high rates are mere perception, say officials of Commercial Taxes department If some traders and businessmen are trying to hoodwink the system by suppressing part of cash based transactions with the connivance of consumers, they will be doing so at their own peril, warns the Commercial Taxes...
Huge numbers of the 9 million US expats living around the world are fed up with the IRS and resent tax filing from their new homes. A poll suggests two-thirds of expats feel they should not have to tell the IRS about their finances if they do not live in...
Kazakhstan and the United States have signed a Model 1 FATCA Intergovernmental Agreement (IGA), which will enable the automatic exchange of financial information on each country’s resident taxpayers to support tax enforcement efforts. The agreement was signed in Astana on September 11, 2017. Kazakh Minister of Finance Bakhyt Sultanov emphasized...
Greece is defying the prevalent trend among the world’s industrialized nations for reducing tax rates in order to boost investment and competitiveness, a report published on Wednesday by the Organization for Economic Cooperation and Development (OECD) has shown. According to the report, in contrast to the majority of...
The governments of Japan and Russia signed a new convention on the elimination of double taxation on September 7. The convention replaces the 1986 agreement between Japan and the former Soviet Union. It lowers withholding tax rates on cross-border income from trade and investment – in most cases to zero...
ECONOMYNEXT – Sri Lanka’s new tax law has provisions that more effectively block companies from trying to dodge taxes by using techniques like transfer pricing, an expert said. The Commissioner-General of Inland Revenue (CGIR) has been given the power to re-examine sch transactions if they are seen to have been...
Canada has implemented the country-by-country reporting requirement for large multinational enterprises (MNEs) contained in the 2015 Final Report on Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) Action Plan. Canada’s legislation is found in s. 233.8 of the Income Tax Act (Canada), and is supported by the...
ECONOMYNEXT – Sri Lanka will charge a 10 percent capital gains tax on investments other than listed shares, under a new inland revenue bill to be effective from April 2018. The principle residence of a person, which has been owned for more than three years and in which a person...
The four biggest economies in the Eurozone – Germany, France, Italy, and Spain — demand an end to the erosion of their tax base by means of incorporation in states that facilitate tax avoidance. According to the Financial Times, Bruno Le Maire, Wolfgang Schaeuble, Pier-Carlo Padoan, and Luis de Guindos,...
Operations in the European Union haven’t been easy going for tech companies for quite a long time. While many European countries earlier called for strict privacy regulations and large fines on tech companies for violating them, they have now called for increased taxation for these companies for their operations in...
The EU 28 financial ministers are set to discuss taxation of multinational digital platforms in Tallin on September 15-16, Reuters reports. Companies such as Amazon and Google have designed tax plans that reduce their tax liability in countries they operate. The proposal put forward by the Estonian Presidency proposes to...
BRUSSELS — European Union finance ministers are set to discuss rule changes next week aimed at increasing taxes on digital multinationals such as Google and Amazon, an EU document seen by Reuters said. Online giants are facing increasing pressure in Europe over the low tax they pay, but states have...
The inexact science’ is regarded as the big culprit in reducing global companies’ tax exposure Tax collection from transfer pricing audits has become more common in Africa, with little sign that it will abate in the near future. The transfer pricing policies of many multinational companies have attracted widespread attention...
The Panamanian Government with the aim of improving the competitiveness of the international services industry in Panama and, at the same time, comply with international standards for the effective exchange of information, initiated in 2009 a decisive agenda for the selection of countries with whom tax agreements were going to...
VAT is at the forefront of current tax reforms and soon to be a reality for many regional businesses, as it is expected to be introduced across the GCC from 1 January 2018. The GCC countries have signed up to a unified framework, which will form the basis of the...
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...
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,...
The government said Wednesday that it will toughen its stance against tax evasion by multinational firms by adopting a global agreement in the country’s legal system within the year. In the mid-to-long term tax policy plan announced Wednesday, the finance ministry said that it would submit bills to enact “OECD...
MEDIUM and large businesses with multinational ties will soon have to start supplying the South African Revenue Service (SARS) with more detailed reports of their relationships and transactions with connected entities residing in other countries. SARS has beefed up its Transfer Pricing Division and is now actively involved in the...
The Internal Revenue Service has signed a contract with a company called Chainalysis that offers software for analyzing and tracking bitcoin transactions. The IRS has been pushing for ways to tax bitcoin transactions. In 2014, it issued basic guidance in Notice 2014-21 stating that virtual currencies such as bitcoin should...
The caretaker government may make the Netherlands a less attractive location for international business because of changes to the corporate tax system, the employers’ organisation VNO-NCW and tax advisers have warned, the Financieele Dagblad said on Monday. The employers and Dutch Order of Tax Advisors say the government is choosing...
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...
The Federal Court of Canada has ruled that the Canadian Revenue Agency may not conduct further in-person interviews with representatives from a multinational corporation concerning its transfer pricing affairs, having already discussed earlier tax years. Cameco Corporation declined to produce approximately 25 personnel for oral interviews in relation to an...
The Internal Revenue Service has extended the deadline for foreign financial institutions to have renewed their FFI Agreements, it has emerged. As reported, the original deadline was 31 July. However, accounting industry sources have flagged up the fact that the Internal Revenue Service is now stating that the deadline for...
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...
African nations will have more resources at their disposal to meet the Sustainable Development Goals if their national revenue authorities can boost tax collection. The United Nations Economic Commission for Africa estimates that the continent loses more than $50 billion through illicit financial outflows per year, much of this linked...
PERTH (miningweekly.com) – US oil and gas major Chevron has withdrawn its High Court appeal over a A$340-million bill from the Australian Taxation Office (ATO). The withdrawal means that the Full Federal Court decision of April is now final. The company in May turned to the High Court after a...
Bizlive cited a report from the Foreign Investment Agency (FIA) as showing that the British Virgin Islands alone registered $1 billion worth of FDI in the first seven months of the year, raising its total accumulative investment capital to $21.4 billion, ranking fifth among countries and territories with the highest...
Banker’s Toolbox, Inc., the leader in Bank Secrecy Act anti-money laundering compliance solutions for financial institutions, announced today the launch of its Due Diligence Manager solution for Beneficial Ownership. This extension of the existing BAM+ platform delivers exciting and holistic features including a completely flexible question builder and automated periodic...
Mexico has introduced new substance-over-form procedures that change the country’s formal approach into one more compliant with the BEPS Project. Taxpayers should take note of these developments as they may impact tax disputes, writes Bernardo Ramírez and Valentín Ibarra of Chevez, Ruiz, Zamarripa y Cía. Resulting from a G20 world...
INTRODUCTION HMRC have successfully challenged the offshore residence of Jersey companies holding UK real estate. In the case of Development Securities, the First Tier Tribunal held that Jersey companies set up to hold UK real estate were resident in the UK for tax purposes. This case serves as a timely...
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....
Ireland has published guidelines for requesting Mutual Agreement Procedure (MAP) assistance. The guidelines, issued in early August, set out the legal basis for requesting MAP assistance as well as: the process through which taxpayers can request assistance from Ireland’s Competent Authority (the Revenue) the possible outcomes resulting from a request...
The UK tax authority, HM Revenue and Customs (HMRC), has warned taxpayers to avoid disguised remuneration schemes that attempt to recharacterize loan arrangements to avoid the 2019 loan charge on disguised remuneration. “HMRC is aware of schemes that claim to avoid the 2019 loan charge on disguised remuneration. These schemes...
The Irish Government is said to be nearing a deal with Apple that would protect the state from any losses that could arise while it holds in escrow the “state aid” money the EU has ordered the tech giant to pay back. Bloomberg reported that an individual familiar with the...
America has formally agreed to share detailed information of companies with the Australian government’s Tax Avoidance Taskforce. This means authorities get access to additional intelligence to track down US-based multinationals. This month, US authorities signed a country-by-country report exchange deal with Australia. It seeks to give authorities a broader picture...
The Budget Advocacy Network (BAN) has called on the country’s revenue authority to push for better taxation not more taxation. In its Transfer Pricing Report, BAN identified that such efforts hold the potential to stimulate further growth and investment whilst also allowing for increased levels of tax collection. The huge...
Bill would require private companies with more than $100m in turnover to publicly release tax information Six hundred of Australia’s biggest private companies could finally be forced to publish their high-level tax information, under a new push by Labor to repair a notorious piece of legislation. Labor will introduce a...
Brazilian football star Neymar is willing to pay a fine of £1.9 million to settle tax evasion allegations in his country, his lawyer said Friday. The 25-year-old wants to leave the fight with Brazilian authorities behind him as he prepares for a new professional life with Paris Saint-Germain after his...
