The number of multinational companies warning investors about the risk of higher taxes doubled in the past year, according to analysis by the Financial Times. Nearly a fifth of the US companies who warned on taxes were technology companies, the Financial Times found in a study of company filings. A… – Continue reading
Both the US and the global forum working on automatic exchange of information under OECD have endorsed the data safeguards put in place by India New Delhi: India’s tax systems have withstood international scrutiny over data confidentiality and other safeguards put in place by the government before the revenue authorities… – Continue reading
Global international tax takes from multinational companies will almost certainly increase in the next 5-10 years as governments around the world look to level the taxation playing field. Commenting on the New Zealand Herald’s series examining ‘the tax gap’ – multinationals channelling earnings to lower tax regimes, disadvantaging some of… – Continue reading
Kenya has received global recognition from the Organisation for Economic Co-operation and Development (OECD), following the appointment of James Karanja, a career Kenyan tax administrator to lead the recently established Tax Inspectors Without Borders (TIWB) Secretariat. TIWB is a global scope initiative, that was launched mid last year at the… – Continue reading
Investors alerted to risks of higher payments as crackdown closes loopholes A global crackdown on tax avoidance has forced a surge of warnings by multinational companies that higher payments are set to hit their earnings. A Financial Times analysis of company filings revealed that more than twice the number of… – Continue reading
European Union member states are taking the lead on implementing the Organisation for Economic Co-operation and Development’s recommendations under the base erosion and profit shifting (BEPS) project, a new EY report says. EY’s Outlook for global tax policy in 2016 report highlights that, of the 14 jurisdictions (37 percent) either… – Continue reading
Court cases likely over interpretation of the new levy proposed in the Budget for digital economy The government’s plan to expand the scope of equalisation levy proposed in the Union Budget, seeking to bring more transactions in the digital economy under the tax net, has left many e-commerce players fuming…. – Continue reading
The Federation of Korean Industries (FKI) has disclosed that 81 percent of respondents to a survey of South Korean companies professed that, although they were aware of the OECD’s base erosion and profit shifting (BEPS) project, they were not, as yet, making any preparations. The South Korean Government is preparing… – Continue reading
Multinationals with turnover of more than €750 million would have to publish profit and tax details on their websites under new European Commission plans, the Financial Times has reported. According to plans seen by the Financial Times, the Commission would impose the requirement on companies with subsidiaries in Europe as… – Continue reading
The American Institute of CPAs has written to the Internal Revenue Service recommending some changes in the IRS’s proposed regulations for country-by-country reporting by multinational corporations of financial information to curb tax avoidance. The proposed regulations were issued last December as part of an effort by the Organization of Economic… – Continue reading
Private equity (PE) populism looks to be in the news again – though in a context that’s unlikely to win too many votes for the instigators. This time it’s the UK, and Chancellor George Osborne’s latest budget. The UK Budget 2016 (the Budget) includes a significant reduction in the UK… – Continue reading
The ways of doing business in a digital economy have evolved rapidly. Traditional tax norms, effective in addressing issues in a world before high-paced technological and e-commerce, are increasingly becoming outdated. Taxation of e-businesses has been a globally identified challenge with tax authorities acknowledging that corporates in this disruptive environment… – Continue reading
The Treasury recently released a revised U.S. Model Income Tax Convention (the “2016 Model”), the U.S. starting point for bilateral treaty negotiation, last updated a decade ago. In May 2015, the Treasury circulated several proposed changes in draft form. Those proposals generally survive in the 2016 Model, although the Treasury… – Continue reading
THAILAND HAS no plan to adopt any time soon the three-tiered approach to transfer-pricing documentation recommended by the Organisation for Economic Cooperation and Development. However, large Thai multinational enterprises (MNEs) with subsidiaries operating in countries that are members of the OECD and/or Group of 20 will find that they will… – Continue reading
New tax regulations dealing with the issue of BEPS (Base Erosion and Profit Shifting) may have a disproportionate impact on the real estate development sector as they are implemented in the UK. The concept of BEPS originates from the OECD and the G20 nations. The intention is to deal with… – Continue reading
Thomson Reuters Checkpoint has just released a special report, European Commission Presents Anti-Tax Avoidance (ATA) Package, summarizing the ATA Package to help businesses plan for the latest developments in advance of implementation. On January 28, 2016, the European Commission presented its Communication on the Anti-Tax Avoidance Package. The goal of… – Continue reading
In the final session of the two day Global Tax Conference at Dublin Castle yesterday, a senior Canadian tax advisor used the analogy of children playing football to describe the relationship between multinationals and government when it comes to tax. In a kids football match, he said, when the ball… – Continue reading
The amount of tax multinational companies pay – and the amount they don’t pay – has become highly controversial, writes RTÉ’s Economics Correspondent Sean Whelan. This is mainly as a result of public outrage over legal tax avoidance schemes that big companies can use to shelter vast amounts of money… – Continue reading
EU countries will exchange information on the tax affairs of multinational companies under new rules backed by EU finance ministers aimed at stopping big companies avoiding paying their fair share into government coffers. The rules, that should take effect later this year, are a response to growing concerns about corporate… – Continue reading
Following the release of the anti-tax-avoidance (ATA) package on January 28, 2016 by the European Commission, the Dutch Presidency of the Council of the European Union presented an EU-Base Erosion and Profit Shifting (BEPS) Roadmap (the Roadmap) to the Members of the High Level Working Party on Tax issues. The… – Continue reading
The International Chamber of Commerce (ICC) has expressed deep approval for the Organization for Economic Cooperation and Development’s (OECD) plan to allow all countries to participate in its Base Erosion and Profit Shifting (BEPS) plan. BEPS is an international policy proposal designed to counteract the negative effects of multinational companies’… – Continue reading
Debt planning and restructuring is a common mechanism to minimize taxable income by increasing deductions among different entities in a multinational group of companies. As interest on debt is generally a deductible expense of the payor and taxed in the hands of the payee, groups may create intercompany loans to… – Continue reading
Governments around the world want more tax income. There is a widely held feeling that many international companies are basing themselves in places like Luxembourg, Ireland, and the Netherlands to avoid tax. The world’s largest countries have a plan and things will change. What will be the effect on Luxembourg,… – Continue reading
The International Chamber of Commerce (ICC) welcomes the Organisation for Economic Co-operation and Development’s (OECD) plan to allow all countries to participate on an equal footing with OECD and G20 countries in the implementation of the OECD/G20 Base Erosion Profit Shifting (BEPS) plan. The framework announced by the OECD early… – Continue reading
With the adoption of the BEPS package, OECD and G20 countries laid the foundations of a modern international tax framework under which profits would be taxed where economic activity and value creation occurs. It is now time to focus on implementation of the recommended changes in a consistent and coherent… – Continue reading
In Shanghai, Wolfgang Schäuble is urging his fellow G20 countries to put new rules to tackle tax avoidance into law. Back home, business leaders worry that German companies could be left exposed by the new rules if they are introduced unilaterally or go too far. The finance ministers of the… – Continue reading
If a member of Congress told you that he was going to use some of your hard-earned tax dollars to support an international organization that demands that you pay higher taxes, what would you say? Unfortunately, the question is not hypothetical, because that is exactly what is now happening. Congress… – Continue reading
A “controlled foreign company” (CFC) is, as the name implies, a foreign company or subsidiary owned by a parent company which is situated in a country different from the parent company’s country of residence. The tax laws of many countries, including the Philippines, do not tax the CFC’s parent company… – Continue reading
Tax function of an organisation was traditionally run from the tax director’s room. Transfer Pricing (TP) was governed by contracts between related parties and this at times resulted in profits moving to legal entities that had contractual rights but had no significant people functions. There were instances of IP Holding… – Continue reading
The OECD’s base erosion and profit shifting (BEPS) project – which is aimed at closing gaps and mismatches in tax laws that conspire to reduce corporate tax liability – is a game-changer for treasury planning. The final reports of the BEPS Action Plan, announced by the Organization for Economic Cooperation… – Continue reading
When a rock-star French economist comes to our country to tell us that the surest way to fix inequality is to tax the hell out of the privileged, they are guaranteed a sympathetic audience. And so we will partly have Thomas Piketty to thank when Pravin Gordhan introduces tax hikes… – Continue reading
Transfer pricing (TP) issues have never been such a critical part of the global economic agenda as they are today. Following the release of the report addressing Base Erosion and Profit Shifting (BEPS) in February 2013, OECD and G20 countries (including India) adopted a 15-point Action Plan to address BEPS… – Continue reading
If January is a month of New Year resolutions, February can be said to be a month of New Financial Year expectations with Indian Government announcing its fiscal policy strategy, including taxation regime for the next financial year. The Union Budget of 2015-16 was the first full budget presented by… – Continue reading
Any country that agrees to adopt the OECD/G20 base erosion profit shifting (BEPS) project minimum standards and pay an annual fee will be allowed to participate in future BEPS project work, according to a plan agreed to by the OECD today. The OECD’s framework for BEPS plan implementation, to be… – Continue reading
Is India back on the world map as a lucrative investment jurisdiction? Does the world see the Make in India dream becoming a reality? Well, the $222 billion investment pledges received during the Make in India week do resonate the revived positive sentiment! In fact, recent policy measures have clearly… – Continue reading
Malta has always insisted it is no tax haven, but it employs a system which allows foreign shareholders to claim a six-sevenths’ refund on their taxed dividends, taxed at the maximum 35%. There’s a new battle lining up for the Maltese government inside Brussels: an aggressive fight against tax avoidance… – Continue reading
The oil price slide is driving tax reforms across the region as Arabian Gulf economies seek to shore up a potential US$700 billion deficit. All six Arabian Gulf states are planning to introduce Value Added Tax (VAT) collectively. Various other tax reforms are also underway. The IMF warned in October… – Continue reading
Malta’s deficit will go down to an unprecedented 1% of GDP and debt will be cut to 64.3% of GDP in 2017. Minister for Finance Edward Scicluna has welcomed Malta’s stable ‘A’ Fitch Rating , saying the latest report, published last night, “shows that Malta’s economy will keep on growing.”… – Continue reading
The 15 part action plan aims to tackle global inequalities in taxation income, increasing transparency for tax administrators and significantly improving Multinational Enterprises’s compliance. With tax regulations of large corporations at the forefront of all policy makers’ minds, this latest endeavour from the OECD and G20 will address the varying… – Continue reading
Last month the European Commission launched its Anti Tax Avoidance Package, propelled by unprecedented political support for the fight against perceived tax avoidance by multinationals. In it the European Union stresses its full support for recent recommendations of the Organisation for Economic Cooperation and Development’s (OECD) BEPS project and it… – Continue reading
As part of strategic effort to tackle cases of international tax avoidance and evasion, Kenya has joined the league of 93 global nations; united to address the economic vices and has now signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. The signing of the crucial agreement, last… – Continue reading
In the aftermath of the latest global financial crises, government have sought to recoup lost revenue through tax reform. This has put the spotlight on the issue of gaps in the current international taxation system that created opportunities for Base Erosion and Profit Shifting (BEPS) schemes. Simply put, BEPS are… – Continue reading
EU finance ministers will attempt to reach agreement by March on a directive requiring EU-wide country-by-country reporting for large multinationals and by July on a directive requiring EU states to adopt six anti-tax avoidance measures for corporations, Jeroen Dijsselbloem Dutch finance minister and president of the Eurogroup announced at an… – Continue reading
Malta’s Minister of Finance, Edward Scicluna, has expressed disappointment that the proposed EU Anti-Tax Avoidance Directive was not accompanied by an impact assessment for member states. Speaking at the ECOFIN meeting of EU Finance Ministers in Brussels, he said that such an impact assessment is necessary, including to measure the… – Continue reading
In line with international developments, the Italian Government has been focusing on fighting tax evasion and avoidance in recent years. Studies and in-depth analyses on evasion and aggressive avoidance, conducted under the OECD BEPS project, which was delivered in October 2015, have led to the issuing of a series of… – Continue reading
Action Plan 15 of the Organisation for Economic Co-operation and Development’s (OECD’s) Base Erosion Profit Shifting (BEPS) Project discusses the desirability and technical feasibility of a multilateral instrument to implement the treaty-related measures in the other BEPS Action Plans (discussed in previous articles in this column). Action Plan 15 proposes… – Continue reading
EU countries may have lost out on more than €1 billion in tax revenues between 2009 and 2014 due to aggressive tax strategies by furniture giantIkea, a new report has claimed. The report, commissioned by the Green/EFA group in the European Parliament into the tax affairs of the private company,… – Continue reading
If Swiss banking secrecy laws gave Switzerland the world banking capital status, Monaco’s residence policy gives its realtors a thriving business. What is common between the Canadian Raonic who lost in the Australian Open semifinals and the Serbian Djokovic who won it? Well, they are both residents of Monaco, and… – Continue reading
The Australian Treasury on February 11 opened a consultation on whether Australia should adopt into law final OECD/G20 base erosion profit shifting (BEPS) transfer pricing recommendations. The goverment seeks feedback on the adoption of the BEPS report, Alleging Transfer Pricing Outcomes with Value Creation, which has been approved by G20… – Continue reading
Amid ongoing debate in the UK on “corporate tax deals,” the British Chamber of Commerce has said the UK needs to comprehensively simplify business tax rules and eliminate loopholes that are exploited in aggressive tax avoidance schemes. On February 11, on the same day the Public Accounts Committee took evidence… – Continue reading
