Israel has joined 90 other countries in signing up to the OECD’s instrument to combat offshore tax avoidance and increase transparency in tax matters. The middle-eastern country became the 91st jurisdiction to sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters yesterday, which enables the exchange of information,… – Continue reading
Global taxpayers can expect to pay more tax in the years ahead. Many governments worldwide continue to update their tax legislation and expand their tax systems to repay debt and pay for increased social welfare, even as the memory of the last global financial crisis lingers. These are the conclusions… – Continue reading
Greater China, Southeast Asia Seen as Global Leaders in Use of Offshore Vehicles, Drawn by Efficiency & Legal Frameworks Key Highlights: OIL’s sixth annual survey shows: The offshore industry will be a leaner, more resilient and confident member of the global economy by 2020, driven by demand from increasing numbers… – Continue reading
The Senate Finance Committee and the House Ways and Means Committee’s Subcommittee on Tax Policy today both announced hearings relating to the OECD’s base erosion and profit shifting (BEPS) project. Both hearings are scheduled for Tuesday, December 1, 2015. SENATE FINANCE HEARING According to today’s release, the Senate Finance Committee’s… – Continue reading
Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading
New Zealand will take steps to prevent base erosion and profit shifting (BEPS) while at the same time ensuring that the country continues to be a good place to do business, Todd McClay, Minister of Revenue, has said. McClay was addressing a recent conference organized by the Chartered Accountants Australia… – Continue reading
On 17-18 November 2015, a new regional meeting as well as a governmental workshop on BEPS was held for the Latin America and the Caribbean region to discuss the outcomes of the BEPS Project, and the ways that the countries can explore to be involved on an equal footing in… – Continue reading
Protecting the tax base of extractive industries, moving toward more responsive and flexible fiscal regimes, and improving international cooperation have become priorities in the Andean region, as commodity prices and revenues from extractive industries continue to decline, participants at a recent IMF conference heard. The three-day conference, Determining the Tax… – Continue reading
Steptoe & Johnson LLP Today, Senate Finance Committee Chairman Orrin Hatch (R-UT) announced that the Senate Finance Committee will hold a hearing on December 1, to examine the Organization for Economic Cooperation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) reports and the European Union’s (EU) State Aid investigations… – Continue reading
Taxpayers in Romania and throughout the world can expect to pay more tax in the years ahead as governments expand their tax systems to repay debt and pay for increased social welfare, and international efforts to update tax legislation for the 21st century take hold. These are the conclusions of… – Continue reading
Pfizer $160bn purchase of Allergan will see firm move HQ to Dublin Ireland’s exchequer is in line for an annual boost of up to €620 million following the announcement that Pfizer is buying rival Allergan in a $160 billion (€151 billion) deal. The takeover will see Pfizer move its corporate… – Continue reading
The World Bank has placed India twelve notches higher than last year in its Ease of Doing Business rankings for 2016. This comes close on the heels of the country’s sixteen place leap on the World Economic Forum’s Global Competitiveness index. These rankings underline the impact of the recent spate… – Continue reading
Hong Kong’s Secretary for Financial Services and the Treasury, K C Chan, has emphasized that the Government is committed to complying with the latest international tax developments, including on tax transparency and tackling base erosion and profit shifting. In his speech to the Taxation Institute of Hong Kong 2015 CTA… – Continue reading
Professional services firm PwC has predicted that UK Chancellor George Osborne will introduce an “apprenticeship levy” and seek to lessen the impact of tax credit cuts when he delivers his Autumn Statement on November 25. In his Summer Budget, Osborne pledged that the Government would “introduce an apprenticeship levy on… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) today released annual statistics on the mutual agreement procedure (MAP) caseloads of all its member countries and of non-OECD economies that agree to provide such statistics for the 2014 reporting period. Today’s OECD release explains: The MAP statistics correspond to the 2014… – Continue reading
On 10 November 2015, the Danish Ministry of Taxation introduced a draft bill (bill no. L46) including an amendment to section 3B of the Danish Tax Control Act (skattekontrolloven). The purpose of the proposed amendment is to implement Action Point 13 of the BEPS Initiative (Guidance on Transfer Pricing Documentation… – Continue reading
Through tweaks to the Model Tax Convention, the OECD believes its work on profit shifting will stem elaborate structures, such as commissionaire arrangements, used by large multinationals to avoid the creation of a permanent establishment. The Organization for Economic Cooperation and Development, however, responded to concerns from taxpayers by narrowing… – Continue reading
The U.K. and the U.S. governments will adopt different approaches to implementing the OECD’s final package of measures to tackle base erosion and profit shifting, panelists at a London forum said. The U.K. government considers an inclusive, multilateral instrument to upgrade bilateral tax treatments as the “best way” for countries… – Continue reading
Big name companies have faced a lot of criticism from the media about the low taxes they pay in some countries. Lately, the Organisation of Economic Cooperation and Development (OECD) has finalised a set of recommendations to stop base erosion and profit shifting (BEPS). The rules are aimed at curbing… – Continue reading
The OECD’s final report on Action 13 under the base erosion and profit shifting project—which calls for countries to adopt a country-by-country reporting template, master file and local file—has the potential to be one of its “greatest legacies.” Marlies de Ruiter, head of the Organization for Economic Cooperation and Development’s… – Continue reading
“India’s concerns are known…there can be no compromise on the issue of terror…India’s longstanding position is that there is no good or bad terror and all forms of terrorism are unacceptable and must be fought by the global community as well as each and every country”, the source told reporters…. – Continue reading
The North will have its own 12.5pc corporate tax rate from 2018. This means that it will compete harder against the Republic for FDI projects, writes Dan White The 12.5pc company tax rate will no longer be confined to the southern part of the island. Last week’s ‘Fresh Start’ agreement… – Continue reading
We are all aware of “base erosion and profit shifting” or “BEPS”. On 5 October 2015, the OECD released its final reports in connection with its BEPS Action Plan including its final report on Action 15 dealing with the development of a multilateral instrument to modify bilateral tax treaties (“Final… – Continue reading
The UK’s All-Party Parliamentary Group on Responsible Tax will on November 23 launch a public consultation on the impact of the OECD’s base erosion and profit shifting on the tax rules in place in the UK. Led by Margaret Hodge, the former Chair of the UK’s Public Accounts Committee, the… – Continue reading
MUMBAI: India’s forthcoming budget may draw from some of the recommendations, especially in the realm of transfer pricing, contained in the final package of ‘Base Erosion and Profit Shifting’ (BEPS) measures, rolled out in October. Certain anti-abuse measures, such as thin capitalization, which for tax purposes disallows interest payments beyond… – Continue reading
Introduction Tax exemptions Eligibility Trademarks Calculating tax benefits Eligible costs Introduction At the end of 2014, the government presented the 2015 budget, which introduced a ‘Patent Box’ tax regime in line with similar schemes adopted in other European countries. It applies to corporate income tax and regional tax on productive… – Continue reading
On 18 June 2013, the Progressive led government issued a press release titled, “Cayman’s Action Plan Includes Beneficial Ownership”. The press statement came on the heels of the UK taking over the Presidency of G8, at the 17-18 June 2013 G8 Summit in Northern Ireland. The most interesting part of… – Continue reading
The OECD/G20 project on BEPS provides governments with solutions for closing the gaps in existing international rules that allow corporate profits to artificially shift to low or no-tax environments, where little or no economic activity takes place. Finance Ministry today said it is prioritising implementation of certain Base Erosion and… – Continue reading
CANBERRA – Several multinational companies have approached the Australian Taxation Office to negotiate before the Coalition Government’s tougher anti-avoidance laws take effect in January, tax commissioner Chris Jordan has said in opening remarks to the Senate inquiry into corporate tax avoidance. While not naming the companies, Jordan said he expects… – Continue reading
Nigeria’s tax authority—the Federal Inland Revenue Service—has incorporated into its tax audit procedures certain of the recommendations included in the OECD’s base erosion and profit shifting (BEPS) project. For instance, the tax authority is scrutinizing transactions between Nigerian subsidiaries and their foreign related parties, especially those related parties located in… – Continue reading
Employees in tax functions need to fundamentally change the way they use and gather data if they are to meet the growing demands on business of tax transparency, reform and technology enabled decision making. PwC’s latest research into the Tax function of the future – Unlocking the power of data… – Continue reading
Earlier this week the heads of state of the 20 largest global economies have agreed to adopt the 15 BEPS action points in their respective countries. Ample reason to take a closer look at the details and implications of one of the most far-reaching upcoming tax adjustments. Action 4 of… – Continue reading
Measures Will Impact Financial Services, Investment Fund, Aviation Leasing and Other Sectors G20 finance ministers last week finally approved the wide-ranging “BEPS” reforms to the international tax system. The measures include a proposed new OECD treaty definition of “Permanent Establishment” under which the mere negotiation of contracts could create a… – Continue reading
Tax administrators want to maximise the amount of revenue collected without stifling the county’s competitiveness as a business destination. How should ASEAN countries navigate changing international conditions to meet this goal? By Rebecca Tan – As Benjamin Franklin once famously said, “In this world, nothing can be said to be… – Continue reading
Hong Kong is tipped to become the world’s largest offshore corporate services centre by 2020, helped ironically, by the industry’s own struggles against reform demands coming from western governments and pressure groups. On notice after high profile money laundering and tax avoidance scandals, traditional offshore havens like the British Virgin… – Continue reading
18 November 2015 – The Group of 20 (G20) leaders have called for more collective action to achieve strong, sustainable and balanced growth that can be universally beneficial. In a communique issued at the end of the summit, the leaders agreed that not only do they have to do more… – Continue reading
The new tax treaty signed between Australia and Germany on 12 November 2015 is the first tax treaty Australia has signed that comprehensively incorporates the proposals in the OECD base erosion and profit shifting (BEPS) final recommendations. Some notable BEPS-related changes in the new Australia and Germany treaty include: The… – Continue reading
American Innovation Matters (AIM), a coalition of companies that includes Cisco, Boeing, Intel, Oracle and Facebook, has released a statement pushing for the introduction of a US patent box, or an “innovation box” as it is known in the United States. The statement looks at the endorsement on November 16… – Continue reading
Google is said to have evaded paying an estimated $1.3 billion earned from selling apps in Korea based on the argument that their server is based in Ireland. The so called ‘Google Tax’, also known as the Base Erosion & Profit Shifting (BEPS) regulation, has been adopted this week by… – Continue reading
Tax Commissioner Chris Jordan says multinationals are already approaching the Australian Taxation Office to negotiate before the Turnbull government’s tougher anti-avoidance laws take effect in January, and he expects the office to reap $1.1 billion from them. We at the ATO acknowledge Australia needs investment by foreign companies in infrastructure… – Continue reading
PwC Australia Australian Taxation Office New or updated materials on ATO website, including: Decision impact statement on McGrouther & Anor v Commissioner of Taxation case concerning whether a taxpayer can waive or withdraw a notice given to the Commissioner under s14ZYA(2) of the Taxation Administration Act 1953 (requiring the Commissioner… – Continue reading
MEPs grilled eleven multinational companies on their corporate tax practices in a five-hour debate with the Special Committee on Tax Rulings on Monday. These companies had declined the committee’s first invitation to appear before it, but later changed their minds and accepted its last chance invitation. Of the 13 original… – Continue reading
President Park Geun-hye called Monday for a careful adjustment of monetary policies of advanced countries amid lingering worries over a potential Fed rate hike. Last month, the U.S. Federal Reserve kept interest rates at near zero due to global headwinds but suggested that it could raise rates by the end… – Continue reading
MELAKA, Nov 17 (Bernama) — The Inland Revenue Board (IRB) has highlighted the transfer pricing (TP) and abuse of treaties in base erosion and profit shifting (BEPS) issues at the 36th Commonwealth Association of Tax Administrators Conference (CATA) here today. IRB, in a statement today, said CATA members were serious… – Continue reading
Foreign investors are still concerned about the retrospective taxation in India, but the concerns have alleviated a little due to assurances by the government, says John Hobster, global head (transfer pricing), EY. He tells Dilasha Seth that in terms of transfer pricing, things are changing in India not only at… – Continue reading
On 30 October 2015, the Global Forum on Transparency and Exchange of Information for Tax Purposes published a supplementary peer review report for Luxembourg. Luxembourg, which was rated “Non-Compliant” in November 2013, has since implemented a number of recommendations made by the Global Forum, leading to an upgrade of its… – Continue reading
The need for robust, well-informed intangible asset valuations for the purpose of transfer pricing is becoming ever more invaluable for MNEs TRANSFER pricing has been the buzz-word of the moment with extensive media coverage in recent years of multinational enterprises (MNEs) repositioning profits to more favourable tax jurisdictions. This movement… – Continue reading
2nd Symposium of CR for transfer pricing The 2nd Symposium Transfer Pricing organized by EY Greece, exactly one year after the successful organization of the 1st Symposium was intended as the developments in transfer pricing in Greece and international tax developments, focusing on the recently finalized OECD Actions tackling Erosion… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) has described its newly unveiled Base Erosion and Profit Shifting (BEPS) Action Plan as a “change of paradigm.”1 A few very large global groups aside, a more apt description may be a minefield for the unwary. BEPS has received considerable air time… – Continue reading
When in 1915 Albert Einstein developed the general theory of relativity, providing a unified description of gravity, the impression was that said theory applies to big objects (like stars) as well as to small objects (subatomic particles). But during the following 15 years it was discovered that in the “small… – Continue reading
