As part of the aim to sustainably meet the highest international standards in the tax field, the Minister of Finance Dr. Jose Jardim has joined the Base Erosion and Profit Shifting agenda of the OECD. In this context, the section with regard to the Common Reporting Standards concerning the automatic… – Continue reading
Multinational companies are making strides in preparing for radically changed cross-border tax and transfer-pricing reporting rules as compliance deadlines near, research by Thomson Reuters suggests, but uneasiness remains amongst tax executives about their readiness. The new rules will require multinational enterprises with annual revenues of €750 million ($830 million) or… – Continue reading
On 12 July 2016, the Council adopted new rules addressing some of the practices most commonly used by large companies to reduce their tax liability. The directive is part of a January 2016 package of Commission proposals to strengthen rules against corporate tax avoidance. The package builds on 2015 OECD… – Continue reading
The OECD has released its standardised IT-format for the exchange on tax rulings (ETR) between jurisdictions to meet the new tax framework following adoption of BEPS Action 5 on countering harmful tax practices more effectively The ETR XML Schema is part of the OECD’s work to ensure the swift and… – Continue reading
The Irish Revenue has released guidance on how it will exchange information on the tax rulings it grants. Revenue eBrief No.65/16, which was released on July 5, 2016, sets out Revenue’s arrangements for implementing Council Directive (EU) 2015/2376; and the OECD’s framework for the compulsory spontaneous exchange of information in… – Continue reading
Fast-fashion retailer H&M is one of a growing number of multinationals locking in their Australian tax, as debate continues about whether Australia has stopped corporate tax leakage. H&M’s strongly performing Australian subsidiary has entered into a four-year Advanced Pricing Agreement (APA) with the tax office that expires on November 30,… – Continue reading
The European Union’s Anti-Avoidance Directive, which has to be put into national legislation by 2019,is aimed at plugging loop-holes in tax systems which allow large corporations to legally avoid paying tax. While Malta has been criticised for offering competitive tax rates, despite the openness and uniformity of such competitive rates,… – Continue reading
Two-thirds of corporate tax executives surveyed say their companies are proactively preparing for the onslaught of new tax regulations resulting from the Base Erosion and Profit Shifting (BEPS) Action Plan. That`s a 22% increase in the past year. In Thomson Reuters 2015 BEPS Readiness Survey, 54% of respondents said they… – Continue reading
A further five countries have signed the OECD’s Multilateral Competent Authority Agreement for the automatic exchange of country-by-country (CbC) reports, bringing the total number of signatories to 44. The Agreement allows all signatories to bilaterally and automatically exchange CbC reports with each other, as contemplated by base erosion and profit… – Continue reading
THAI MULTINATIONAL companies will be impacted on their cross-border business activities due to rapidly evolving tax laws in Europe and Asia-Pacific. For instance, the European Union (EU) achieved a groundbreaking result on June 20 by agreeing to a package of tax measures to combat corporate tax avoidance, which will be… – Continue reading
Representatives of more than 80 countries and jurisdictions met in Kyoto on Thursday for a two-day conference aimed at going after corporate tax avoidance in the first-ever effort of its kind to include developed and developing countries. The meeting of the Organization for Economic Cooperation and Development’s Committee on Fiscal… – Continue reading
U.S. Companies Will Be Required to Disclose Relevant Financial Data on Country-by-Country Basis to Tax Authorities but not to Public WASHINGTON, DC – Today the U.S. Treasury and the Internal Revenue Service (IRS) published a rule, which will become final tomorrow, requiring the U.S. parent company of large, public and… – Continue reading
European Union member states have struck a deal on new rules designed to eliminate the most common corporate tax avoidance practices. The measures in the Anti-Tax Avoidance Directive target the main forms of tax avoidance practiced by large multinationals and builds on global standards developed by the Organisation for Economic… – Continue reading
The OECD’s Committee on Fiscal Affairs will hold its first meeting under its new inclusive framework for non-OECD and non-G20 territories to discuss the next step on base erosion and profit shifting (BEPS). The two-day meeting will take place in Kyoto, Japan, on June 30-July 1, 2016. The event will… – Continue reading
Singapore is to join the international base erosion profit shifting (BEPS) project as a ‘BEPS associate’ and will adopt the minimum standards under the plan including country-by-country reporting. International tax Tax Corporate tax Tax Disputes and Investigations Asia Pacific South east Asia BEPS refers to the shifting of profits of… – Continue reading
Multinationals suspected of routing Australian profits via Singapore will be outed to tax authorities, with the low-tax nation this week signing up to the global plan to fight tax evasion. Companies including big miners BHP Billiton and Rio Tinto as well as technology giants Apple and Google, have admitted using… – Continue reading
Under the new tax framework, Singapore will implement minimum standards aimed at preventing “aggressive tax planning” by multinationals. Locally headquartered multinationals will soon have to file reports broken down by country as well as income and taxes to the Inland Revenue Authority of Singapore (IRAS). In a statement on Thursday… – Continue reading
Hundreds of policymakers, business executives, and senior tax officials met at the OECD International Tax Conference to discuss the recommendations proposed under the base erosion and profit shifting (BEPS) project and their impact on trade and investment. The conference, which was held in Washington DC on June 6-7, 2016, was… – Continue reading
Members of the EU Parliament have welcomed an EU Commission proposal for an anti-tax avoidance directive but demanded tougher rules on foreign income and stricter limits on deductions of interest payments. They also called for more transparency for trust funds and foundations, common rules for “patent box” tax reductions on… – Continue reading
Most American policymakers believe the U.S. corporate tax system needs reforming – and the facts back up their view The United States’ 39 percent combined statutory corporate tax rate is the highest among the largest 50 economies. The American tax and accounting system has trapped over $2 trillion of deferred… – Continue reading
Sinn Fein’s Matt Carthy has launched a stinging attack on Ireland’s corporate tax regime, arguing that Ireland’s reputation as an “enabler of massive tax avoidance for large corporations” is justified. Addressing the European Parliament in Strasbourg on Tuesday, the Midlands-North West MEP criticised the last government’s move to abolish the… – Continue reading
Recent news of India and Mauritius signing a Protocol to amend their 33 year old tax treaty caused seismic changes in the tax world. Though not completely unanticipated, the change is significant for foreign investors to go back to the drawing board and reassess their structures. The tax treaty between… – Continue reading
CHICAGO – Mid-sized international businesses around the world are afraid that upcoming international tax rules will hike their taxes, increase compliance costs, and interfere with their business strategies. In a report released over the weekend, the international management consultancy firm RSM showed that a significant portion of mid-sized international businesses… – Continue reading
Asia Pacific The January – March edition of tax highlights for the Asia Pacific region highlights industry developments from Australia, China, Hong Kong, India, Indonesia, Korea, Malaysia and Singapore including: Australia’s new tax system for Managed Investment Trusts The final stage of China’s B2V reform to be rolled out from… – Continue reading
Jamaica and Uruguay today signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters and Brazil deposited its instrument of ratification of the Convention on the occasion of the launch of the OECD’s Latin American and Caribbean Regional Programme and the OECD Ministerial Council Meeting. Jamaica and Uruguay became… – Continue reading
In an ongoing effort to increase transparency by multinational enterprises (MNEs), India joined Canada, Iceland, Israel, New Zealand and the People’s Republic of China in becoming the 39thsignatory to the OECD ‘s Multilateral Competent Authority agreement for the automatic exchange of Country-by-Country reports (CbC MCAA). The Country-by-Country Reporting Agreement was… – Continue reading
HMRC is consulting on whether a secondary adjustment rule should be introduced into the UK’s transfer pricing legislation, as the government department continues its clampdown against tax avoidance. The adjustment aims to counter multinationals that do not use the arm’s length principle, reversing any cash benefit that a multinational gains,… – Continue reading
The finance ministry has notified that the equalisation levy (popularly known as Google tax) introduced in this budget, will come into force from June 1. As of now, it will apply to payments for online advertisements made by Indian business entities to non-residents (such as Google,Yahoo, Twitter, Facebook) where the… – Continue reading
The International Chamber of Commerce (ICC) recognizes the efforts of an increasing number of tax authorities to revise their tax policies in response to the international guidelines outlined in the G20 mandated Organisation for Economic Co-operation and Development (OECD) Base Erosion Profit Shifting (BEPS) project. ICC urges national governments to… – Continue reading
The EU’s Economic and Financial Affairs Council (ECOFIN) has been unable to reach agreement on the European Commission’s proposed anti tax avoidance directive. The issue has therefore been postponed until the next ECOFIN meeting in June. The European Commission announced its proposed anti-tax avoidance directive (ATAD) in January. The proposed… – Continue reading
The recent EMEA Conference of Alliott Group, one of the world’s most established international associations of independent accounting and law firms, brought together tax professionals from 28 countries across the world to discuss Base Erosion & Profit Shifting (BEPS), a project led by the OECD and G20 whose Action Plan… – Continue reading
The European Council has adopted a directive on the reporting by multinational companies of tax-related information and exchange of that information between member states, which transposes the OECD’s recommendation on country-by-country reporting (CBCR) into EU law Companies with a total consolidated group revenue of at least €750m (£570m) will be… – Continue reading
Dubai: UAE-based multinationals will start to feel the impact of the OECD Base Erosion and Profit Shifting (BEPS) proposals that come into effect this year, a KPMG seminar on international tax developments has revealed. The BEPS proposals are focused on mitigating tax planning strategies that exploit gaps and mismatches in… – Continue reading
Revenue Minister Michael Woodhouse says the recent signing of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports will help ensure large multinationals pay their fair share of tax by providing for increased sharing of information between revenue authorities. “Some large multinationals often have intricate financial arrangements in… – Continue reading
The OECD’s new emphasis on aligning profits with value creation could induce more companies to take a rigorous approach to their transfer pricing through a value-chain analysis. “The traditional transfer pricing approach is to talk about the routine and the residual, and this is reflected in the way we do… – Continue reading
India had in August 1982 signed the treaty with Mauritius to eliminate double taxation of income and capital gains to encourage mutual trade and investment. Investors must pay taxes on money they earn in India and the domestic economy is now strong enough to depend on any “tax-incentivised route” to… – Continue reading
China said it has signed a multi-lateral agreement to share tax information on multinational companies, paving the way for it to join the fight on global tax avoidance. China signed the country-by-country tax reporting agreement, along with Canada, India, Iceland, Israel and New Zealand, during a meeting of the OECD… – Continue reading
Transfer Pricing in China 2016, the latest publication from China Briefing and Dezan Shira & Associates, is out now and available for purchase through the Asia Briefing Bookstore. Transfer pricing is a reality for any multinational company. As a result of a globalized economy and increasing complexity in business models,… – Continue reading
National Revenue Minister Diane Lebouthillier announced today that the Government of Canada has taken another step to stop the unfair practice of aggressive tax planning by signing an international agreement to implement stronger international reporting obligations for large multinational enterprises (MNEs). Thirty-one other jurisdictions have also signed the agreement. The… – Continue reading
In August 2015, the Organisation for Economic Co-operation and Development (OECD) published the first edition of the Common Reporting Standard (CRS) Implementation Handbook to provide practical guidance to assist government officials in implementing the Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI). The AEOI and CRS… – Continue reading
On 28 January 2016, and in response to the OECD’s Base Erosion and Profit Shifting (BEPS) project, the European Commission published a package of anti-avoidance measures as part of its ongoing plans to ultimately introduce a common consolidated corporate tax base (CCCTB). The package comprises: a draft anti-avoidance Directive, with… – Continue reading
IT’S ALL COMING TOGETHER: Corporate inversions. The Panama Papers. Those European investigations into big-name companies like Apple. And the BEPS project coming out of the Organization for Economic Cooperation and Development. As Tax Pro Katy O’Donnell reports, tax practitioners and wonks might like to say that some of those things… – Continue reading
The Internet and Mobile Association of India’s (IAMAI’s) pushback against the equalization levy on e-commerce transactions introduced in the union budget shows up the difficulty revenue authorities will have when they try to protect their tax base. The last word on this subject hasn’t been said and the original budget… – Continue reading
On October 5, 2015, the Organization for Economic Cooperation and Development (OECD) issued final tax policy recommendations stemming from its Base Erosion and Profit Shifting (BEPS) project. The reports, endorsed by the G20 Finance Ministers on October 8 and by the G20 leaders at their November 15-16 summit, consist primarily… – Continue reading
The mid-May plenary of the OECD’s Forum on Tax Administration will review members’ progress on implementing the OECD’s base erosion and profit shifting (BEPS) recommendations and discuss next steps. Representatives from tax administrations will discuss how to better provide technical assistance to developing countries with the support of international organizations…. – Continue reading
THE OECD, IMF, World Bank and the UN have formed a platform for collaboration on tax to improve tax systems around the world and strengthen BEPS’ grip on developing nations. Designing and implementing standards for international tax matters is high on the agenda for the new platform, with the four… – Continue reading
Genesis of CbC Reporting and How it will Affect U.S. Multinational Enterprises Country-by-country (CbC) reporting is essentially exactly what it sounds like: a report that shows every country where a multinational enterprise (MNE) operates and allocates income, earnings and pays taxes. The CbC report regulations proposed by the Internal Revenue… – Continue reading
In amove towards a more progressive taxation policy the revenue officials have set an aggressive target of resolving about 100 transfer pricing issues by signing advance pricing agreements (APAs) with multinationals this fiscal, people close to the development said. The government, through the Central Bureau of Direct Taxes (CBDT), had… – Continue reading
The European Commission is looking into advance pricing agreements (APAs) given to financing companies and other businesses to see if they constitute illegal state aid, the MNE Tax news site has reported EU competition commissioner Margrethe Vestager told the European Parliament’s TAXE 2 committee that her office has reviewed 1,000… – Continue reading
United Kingdom Budget The United Kingdom (UK) Budget: was handed down on 16 March 2016. Some of the key measures announced include: a reduction in the corporation tax rate to 17 per cent by 2020 (previously due to fall to 18 per cent) more details on the implementation of Base… – Continue reading
