Category: Base Erosion & Profit Shifting

Beps averts collapse of global tax rules, conference told

OECD’s head of tax policy says protectionist measures by national governments had to be avoided The risk of protectionist tax measures being taken by national governments has abated as a result of the OECD’s Base Erosion and Profit Shifting (Beps) project, a key official has told a conference in Dublin…. – Continue reading

Commission to propose that country-by-country tax information be made public

Multinational companies operating in Europe will have to publicly disclose their earnings and the tax paid in each European country if new measures being proposed by the European Commission come into force, The Guardian has reported. The Commission will propose new legislation in April that makes profit and tax information… – Continue reading

Special investigation: Why it’s not just planes that vanish in Bermuda

Journalist Steve Topple investigates Bermuda-based big business tax avoidance and its links with UK political parties – and even some charities LAST WEEK saw the news emerge that everyone’s favourite search engine, Google, only had to pay £97m in back-tax (not the “major success” of £130m as was first reported)… – Continue reading

Senegal signs multilateral agreements to fight tax avoidance and evasion

Senegal on February 4 signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, becoming the 93rd jurisdiction to sign the document, and the Multilateral Competent Authority Agreement for the automatic exchange of Country-by-Country reports, becoming the 32nd signatory to that agreement, the OECD has announced. The Multilateral Convention… – Continue reading

BEPS Action 7: how the OECD’s proposals to redefine a PE could affect multinationals

The OECD’s final reports on the Base Erosion and Profit Shifting (BEPS) Project aim to target aggressive tax planning strategies which have the effect of shifting profits from high tax jurisdictions to low tax jurisdictions. The BEPS Project has been divided into 15 Actions, of which one of the most… – Continue reading

The Tax Avoidance Battle: Nations vs. Multinationals

At least this is the goal – member states safeguarding their social models by preventing trans-border operating multinational companies from avoiding “their fair share” of the tax burden. According to the European Commission, small and medium-sized enterprises in the EU pay 30% higher tax burden than large multinational companies. With… – Continue reading

What’s ahead for 2016 in taxation – will the rubber hit the road?

Many serious reforms have been implemented, and very strong Federal political will, together with strong state-based political consensus, will be needed for any further tax reform in 2016. Over the last couple of years, there has been a lot of talk about tax reform, notably base erosion profit shifting (BEPS)… – Continue reading

McDonald’s halves its tax bill, back pays $78m

McDonald’s Australia was able to more than halve its tax bill last year after routing payments via the low-tax nation of Singapore. Each year McDonald’s reduces its profit, and thus its local tax bill, by paying McDonald’s Asia Pacific based in Singapore, and registered in Delaware, a “service fee” amounting… – Continue reading

U.S. tax authorities approve signing of bilateral APAs with India

The U.S. Internal Revenue Service on Tuesday announced that, starting February 16, its Advance Pricing and Mutual Agreement office will begin accepting requests for bilateral advance pricing agreements between the U.S. and India. This marks a big step forward to ensure tax certainty between the two countries, according to experts…. – Continue reading

OECD BEPS deal of little significance to mining right now

JOHANNESBURG – A data sharing agreement signed by 31 countries – including South Africa – in a bid to enhance transparency by multinational enterprises, is unlikely to have an immediate impact on mining companies. Through the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reporting, signed by members of… – Continue reading

Has globalisation made corporation tax redundant?

The debate about corporation tax intensifies. Is the tax on profit no longer viable now that the global nature of modern business is making it ever harder for individual governments to enforce? Director asks two business leaders, has globalisation made corporation tax redundant? Yes, says Stephen Herring, head of taxation… – Continue reading

Scicluna insists Malta won’t budge from ‘red line’ over tax sovereignty

Finance minister will commission an impact assessment on on how a proposed package by the European Commission to clamp down on aggressive tax planning will impact Malta’s economy Malta will resist any attempt by the European Commission to reduce sovereignty over its own fiscal affairs, finance minister Edward Scicluna pledged…. – Continue reading

Business taxation may need radical change – think tank

Radical changes to business taxation may be necessary to reduce large multinationals’ ability to avoid levies, a respected economic think tank has indicated. In the wake of the row over Google’s deal with HM Revenue and Customs, the Institute for Fiscal Studies (IFS) suggested a shake-up of the corporation tax… – Continue reading

EU targets reinsurance arrangements

The EU’s anti-base erosion and profit shifting (BEPS) proposals could have consequences for captives in Europe, as politicians pinpoint reinsurance arrangements as a means of unfair tax avoidance. The European Commission introduced a range of anti-tax avoidance proposals on 28 January, following the release of the Organisation for Economic Co-operation… – Continue reading

International Tax Disputes: A Ray of Hope

Despite the anticipated tsunami of tax disputes generated by underlying tensions in international taxation, there is reason for hope that appropriate means are being developed to address them efficiently and effectively. Multinational enterprises (MNEs) should be addressing their existing international taxation planning structures in light of coming changes in international… – Continue reading

EU Moves to Close Profit-Shifting Tax Loophole

The European Parliamentary Research Service has estimated that corporate tax-dodging costs the EU between $54.5 billion and $76.4 billion a year. The European Commission has proposed a package of measures to clamp down on corporate tax avoiders that would close a loophole companies have used to shift profits to low-tax… – Continue reading

The Italian Patent Box and Its (Non-) Compliance with OECD Recommendations

The Italian Patent Box regime largely complies with the OECD recommendations to prevent base erosion and profit shifting. Its non-compliant features offer a brief window of opportunity for companies able to take swift advantage of its wide range of qualifying intangible assets. Many countries have implemented specific IP regimes through… – Continue reading

Mandatory disclosure of tax bills closer as Australia joins OECD push

Australia is one of 31 countries to sign an agreement in Paris to confidentially share tax information on multinational companies in a bid to stamp out tax avoidance. The deal comes as Apple has taken advantage of accounting rules in its local business that could allow it to pay virtually… – Continue reading

Fair Taxation: Commission presents new measures against corporate tax avoidance

Today’s proposals aim for a coordinated EU wide response to corporate tax avoidance, following global standards developed by the OECD last autumn. New rules are needed to align the tax laws in all 28 EU countries in order to fight aggressive tax practices by large companies efficiently and effectively. The… – Continue reading

Seoul preparing to levy ‘Google tax’

x The government plans to exchange financial information on multinational firms doing business here with members of the OECD and G20 countries in order to make them pay appropriate taxes to countries where profits are generated, officials said Thursday. The Ministry of Strategy and Finance said that it will follow… – Continue reading

Greater tax transparency for multi-nationals a step closer

The South African Revenue Service (Sars) has published additional record-keeping requirements for large multi-national companies which they will have to comply with in future. Many companies have already included some of the required information in their transfer pricing documentation and on their annual tax returns, but there seems to be… – Continue reading

The tax cut we have to have

Australia must not be blown off course from getting a company tax rate closer to 20 per cent. Corporate tax transparency figures released in December by the Australian Taxation Office should not slow momentum. For the first time, the ATO reported the tax affairs of companies with total incomes of… – Continue reading

31 nations sign agreement on exchange of country-by-country transfer pricing reports

In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading

Global fight against corporate tax avoidance takes off

NEW DELHI, JANUARY 26:Ministers and top tax officials from more than 30 countries including India will sign an international agreement on Wednesday to significantly advance the fight against corporate tax avoidance. This agreement – Multilateral Competent Authority Agreement (MCAA) – will be signed at the OECD in Paris, sources said…. – Continue reading

Irish tax advantages may be banned under new EU rules

Ireland will be forced to ban many of the tax advantages it offers multinationals under proposals to be published by the European Commission tomorrow. This is the first step in an effort to have all EU countries introduce similar tax rules to prevent companies in the 28 member states avoiding… – Continue reading

BEPS project: most Indian MNCs see double taxation going up in short term

NEW DELHI, JANUARY 26:A majority of Indian multinationals see the implementation of base erosion and profit shifting (BEPS) project of the Organisation for Economic Cooperation and Development leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting… – Continue reading

Deloitte’s BEPS survey: Quite an eye opener

NEW DELHI, JAN 25: A majority of Indian multinationals see the implementation of OECD’s BEPS project leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting given that one of the objectives of OECD’s Action Plan on Base… – Continue reading

Intellectual property taxation in post BEPS era

On 5th October 2015, the OECD released its final reports setting out the action plan on Base Erosion and Profit Shifting (BEPS) project, thus concluding the two year project which started at the behest of G20 countries in 2013. The reports are aimed at suggesting the measures to reform the… – Continue reading

Belgian MNCs Gearing Up For BEPS

A vast majority of tax directors working for multinational corporations located in Belgium fear that the base erosion and profit shifting (BEPS) project will lead to higher administrative charges, a survey of over 800 tax directors across Europe has revealed. According to Deloitte’s European Tax Survey, 85 percent of the… – Continue reading

Gulf’s proposed 5% VAT may translate into more than 10% hit on net income: EY

The Gulf countries’ proposed 5% value added tax (VAT) may translate as more than a 10% hit on net income, unless tax efficiencies are improved, according to Ernst and Young (EY). “A 5% rate may not sound like a lot, but if it ends up as an additional cost on… – Continue reading

BEPS rules to be made compulsory from 1 April

India to change laws in Union Budget to make country-by-country reporting mandatory for Indian multinationals New Delhi: India will change laws in the upcoming budget to make country-by-country reporting mandatory for Indian multinationals to ensure they follow so-called base erosion and profit shifting (BEPS) guidelines. The norms were announced in… – Continue reading

Tax-dodging by the superrich is driving global inequality, Oxfam says

Tax dodging by the super-rich is one of the main drivers of global income inequality and must be sharply curtailed, according to a new report from the global nonprofit Oxfam. Citing research by Berkeley economist Gabriel Zucman — a protégé of Thomas Piketty, author of the global bestseller on inequality,… – Continue reading

European Commission plans threaten change to Irish tax system

Ireland’s insistence that it is not a tax haven and that in fact other EU countries have tax regimes that facilitate tax dodging by multinationals will be borne out by a study to be released next week. But while this will be good news to Finance Minister Michael Noonan a… – Continue reading

Infrastructure could suffer ‘collateral damage’ from international tax changes, experts say

FOCUS: Major infrastructure projects and other purely commercial transactions could suffer collateral damage from proposals to reform the international tax system and prevent avoidance by multinationals. Rising tax costs could put additional strain on the viability of key projects. Infrastructure projects are capital intensive and often have a high level… – Continue reading

Multinationals may have to provide global income, tax details to taxman

Budget to implement some of OECD’s standards on profit-shifting NEW DELHI, JANUARY 21:Large multinational enterprises (MNEs) may be required post-Budget to furnish to Indian tax authorities information on their global incomes and taxes. This move — a fallout of India agreeing to OECD’s Action Plan on Base Erosion and Profit… – Continue reading

The Netherlands implements OECD BEPS Country-by-Country Reporting as well as the amendments to the EU Parent-Subsidiary Directive

As from 1 January 2016, new rules have become effective in the Netherlands that require multinational enterprises (“MNEs“) to comply with new transfer pricing documentation requirements, including the obligation to prepare a Country-by-Country Report (“CbC Report“), a Master File and a Local File. These rules essentially implement Action 13 of… – Continue reading

Multinationals may have to provide global income, tax details to taxman

Budget to implement some of OECD’s standards on profit-shifting NEW DELHI, JANUARY 21: Large multinational enterprises (MNEs) may be required post-Budget to furnish to Indian tax authorities information on their global incomes and taxes. This move — a fallout of India agreeing to OECD’s Action Plan on Base Erosion and… – Continue reading

Budget 2016 may introduce BEPS to make tax evasion difficult for MNCs

MUMBAI: In what could lead to an increase in domestic tax liabilities of many Indian conglomerates and multinationals, the government is set to introduce a framework for Base Erosion and Profit Shifting (BEPS), a global agreement to check tax avoidance by multinationals, in the upcoming Budget. Industry sources expect the… – Continue reading

Anger at plans to curb UK’s business-friendly tax regime

Plans to restrict the generous tax treatment of interest costs — a key aspect of Britain’s business-friendly taxation regime — are unnecessary and potentially damaging, companies have told the Treasury. Professional bodies and business groups are voicing fears about the restrictions that are set to be introduced as part of… – Continue reading

FSC calls for 22% company tax

The Financial Services Council has proposed a new tax package calling for company tax to be cut to 22% from its current 30%. The industry body also wants to see “lower, flatter, indexed” income tax rates. The FSC said its tax reform package is designed to “grow the economy and… – Continue reading

Companies anticipate tax authorities to turn aggressive: Survey

NEW DELHI: Indian businesses are anticipating a “more aggressive” stance by tax authorities as their tax arrangements come under greater scrutiny, says a survey. The findings are part of leading consultancy Deloitte India’s BEPS (Base Erosion and Profit Shifting) survey titled ‘Anticipating BEPS India impact’. Indian businesses are anticipating a… – Continue reading

BEPS could cost property industry £660m a year

The introduction of government measures to clamp down on tax avoidance could cost the UK development sector as much as £600m, according to a new study Plans to restrict the tax deductibility could harm investment in debt-reliant industries, the British Property Federation (BPF) warned. Despite supporting the initiative, the BPF… – Continue reading

Dutch EU Presidency To Prioritize BEPS Action

The Netherlands will prioritize action against corporate tax avoidance during its Presidency of the Council of the European Union, from now until the end of June. In a report detailing its plans for its six-month term, the Dutch Government said: “The Netherlands Presidency will prioritize action against tax evasion and… – Continue reading

Property groups say Beps will cost UK sector £660m

UK property companies are seeking changes to the proposed implementation of a global agreement to fight tax avoidance that is set to add £660m to their annual tax bill. Private equity and infrastructure companies are also among those groups facing additional payments under OECD rules on base erosion and profit… – Continue reading

Bloomberg BNA Provides Insights into 2016 U.S and International Tax Policy

ARLINGTON, Va., Jan. 14, 2016 /PRNewswire-USNewswire/ — Bloomberg BNA today announced the publication of the Daily Tax Report’s 2016 Outlook on tax and accounting policy. Dozens of policy experts, along with current and former members of Congress, congressional staffers and federal agency officials provided insights on the year ahead regarding… – Continue reading

2016 CHALLENGES FOR COMPANIES OPERATING IN JERSEY

Last year Jersey cemented its position as a leading centre for companies looking to list – as reflected in the rise in volume and value of Jersey companies listed on exchanges around the world. Here are some challenges that lie ahead in this jurisdiction over the next 12 months. In… – Continue reading

EU to revive common tax base plan, propose binding corporate tax rules

Reforms to corporate tax rules and fiscal transparency will be pursued by EU policy makers in 2016, the EU’s tax commissioner Pierre Moscovici has said. “We have a serious problem with tax avoidance and lack of transparency. Too many people have looked the other way,” Moscovici said. Moscovici told a… – Continue reading

Finland: Transfer pricing documentation rules, country-by-country reporting proposal

The Ministry of Finance on 21 December 2015 released for public comment a proposal to revise the transfer pricing documentation rules and introduce country-by-country (CbC) reporting. The proposal—released as a draft bill—includes CbC reporting, master file and local file requirements, and penalty provisions, and generally follows the recommendations of the… – Continue reading

Commission receives 170 submissions on corporate tax

Information will feed into relaunch of the revised common consolidated corporate tax base The European Commission has received more than 170 submissions on its proposal for a revised common consolidated corporate tax base (CCCTB) ahead of its re-launch later this year. The closing date for the commission’s three-month public consultation… – Continue reading

Budget 2016: Modi government likely to revamp direct taxes to improve ease of doing business

NEW DELHI:The Narendra Modi government, which has pledged a predictable and non-adversarial tax regime, is likely to begin a sweeping revamp of direct taxes in the Budget that Finance Minister Arun Jaitley will present next month. Simplification and rationalisation will be the two themes driving the overhaul, which is aimed… – Continue reading