On September 7, 2015, the local tax court of Cologne (the “Court”) issued an injunction against the German Federal Central Tax Office (“FCTO”) to prevent the FCTO from conducting a coordinated exchange of information with the E6 countries Canada, Great Britain, France, Australia and Japan, which aimed at gathering intelligence… – Continue reading
On 5 October 2015 the OECD published the final package of recommendations to reform the international tax system – the “BEPS” Project. Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations… – Continue reading
On 14 October 2015, the Luxembourg Minister of Finance presented a bill to Parliament on the state budget for 2016. This bill contains several proposals affecting corporate taxpayers. One of the main proposals is the abolition of the intellectual property regime. Similar tax relief systems, known as “IP box” or… – Continue reading
Since Minister Noonan announced in October 2014 that Ireland would introduce a “best-in-class” Knowledge Development Box (“KDB” ), there has been a lot of speculation about ‘how low would he go’. Budget 2016 announced that the rate of tax which will apply for income qualifying under the new KDB will… – Continue reading
JOHANNESBURG – South African has lost R250 billion in the form of service payments over a three-year period, highlighting the significant risk base erosion and profit shifting (BEPS) is posing to the country’s tax base, a South African Revenue Service (Sars) official has said. Almost R80 billion of this were… – Continue reading
A question being considered in Australia—concerning country-by-country (CbyC) reporting—is whether an investment entity is to be excluded from the “group” for CbyC reporting purposes. A preliminary position being advanced is when an entity is not required to prepare consolidated financial statements for financial reporting purposes, then it would be excluded… – Continue reading
Technology company made the largest profit in its history in year to end of September Apple’s latest annual report indicates a substantial increase in the amount of tax it may be paying in Ireland. The latest annual report from Apple, filed last week in the United States, indicates a substantial… – Continue reading
The time of gaming the international tax system is over for big business, following the endorsement of the OECD’s Base Erosion and Profit Shifting (BEPS) project Corporations have to realise that “playtime is over, now you have to come back to school and play with the new instruments”, said Pascal… – Continue reading
04/11/2015 – Uganda today signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters. It is the 8th country of the African continent to sign the Convention and the 90th jurisdiction to join it. Her Excellency, Nimisha Janat Madhvani, Uganda’s Ambassador to France, signed the Convention in the presence… – Continue reading
The President of the European Council Donald Tusk and the President of the European Commission Jean-Claude Juncker, who are representing the European Union at the G20 summit in Antalya (Turkey) on November 15th and 16th, have set out the EU’s agenda in a joint letter sent to EU Heads of… – Continue reading
One year after the announced closing off of the Double Irish tax arrangement, U.S. multinationals once again turned their attention to Dublin as Ireland announced details of the Knowledge Development Box, or KDB. This new component to its corporate tax regime will allow companies to pay a reduced corporate tax… – Continue reading
As procurement organizations evolve, they commonly adopt a different procurement operating model (POMs) at different stages of their development. A global KPMG survey of chief procurement officers (CPOs) found that 83% of organizations changed their POM within the last 5 years and just over half of them over the previous… – Continue reading
Recent legal changes in Qatar must be understood by chief financial officers (CFOs) and finance professionals if businesses are going to be able to address potential risks, the Institute Of Chartered Accountants In England and Wales (ICAEW) said, reports the Gulf Times. The accountancy body partnered with international law firm… – Continue reading
A number of member states are failing to tackle corporate tax avoidance despite media revelations and EU and national-level moves to close loopholes. “It’s clear that in the EU it is business as usual for multinational corporations who want to dodge the rules to lower their tax bills”, said Tove… – Continue reading
Tax systems within the European Union remain largely secretive and opaque despite leaders’ claims that measures are underway to fix loopholes, the European Network on Debt and Development (Eurodad) has said. The coalition of 46 NGOs from 20 European countries including Oxfam, Save the Children and ActionAid said that, while… – Continue reading
Recent legal changes in Qatar must be understood by CFOs and finance professionals if businesses are going to be able to address the potential risks, according to ICAEW. The accountancy body partnered with international law firm Pinsent Masons to host a seminar about Qatar’s recent regulatory changes for senior financial… – Continue reading
Australian taxpayers could get a bill of rights, and better compensation schemes if they have been wronged by the Australian Taxation Office, following a new review by the Inspector-General of Taxation. On Monday, Ali Noroozi launched his review examining whether there’s scope to introduce a taxpayer bill of rights, similar… – Continue reading
MADRID — One part of the move had been long in the works by Grifols, a big Spanish medical company. The other came as a politically fraught surprise. When Grifols, a global leader in blood-plasma products, held a ribbon-cutting ceremony for its new $100 million distribution center outside Dublin last… – Continue reading
As the 2016 Presidential campaign heats up with debates and public appearances replete with the candidate’s opinions on the economy, ISIS, and education, among others, few candidates have mentioned the issue of corporate tax reform, especially as it relates to a level playing field between the U.S. and foreign markets,… – Continue reading
Reducing the corporate tax rate to 25 to 30 percent would discourage profit shifting by multinationals, according to a new report from the Tax Foundation. Up to 35 percent of U.S. corporate tax revenue is lost due to profit shifting, according to some studies. The Organization for Economic Cooperation and… – Continue reading
In late October, public and private sector representatives from Eastern Europe and Central Asia met to discuss collaborating on the implementation of the OECD’s recommendations on base erosion and profit shifting. The meeting was hosted in Tbilisi by the Georgian Ministry of Finance and the Georgia Revenue Service, in co-operation… – Continue reading
Blast waves: smoke billows from the site of an explosion that reduced a parking lot filled with new cars to charred remains at a warehouse in northeastern China’s Tianjin municipality. Most of Bermuda’s major insurers and reinsurers had significant exposures to this disaster. (Photograph by Ng Han Guan/AP Photo) Tianjin… – Continue reading
Gold Fields and Sasol have clinched the top awards in PwC’s Building Public Trust Awards: Excellence in the field of tax reporting in 2015. Gold Fields was the overall winner in the category for tax reporting for multinational companies, while Sasol was announced the overall winner in the category tax… – Continue reading
Russia’s Ministry of Finance has given its reaction to the OECD’s base erosion and profit shifting (BEPS) reports. The Director of the Department for Tax and Customs Policy at the Ministry of Finance, Ilya Trunin, said in a televised interview for Russia 24 that, in 2014, Russia adopted several new… – Continue reading
Opinion is divided on the extent to which corporates are ready for the country-by-country reporting requirements of the OECD’s base erosion and profit shifting project, as well as the work required to ensure compliance. Earlier this month the OECD presented the final package of measures for reform of international tax… – Continue reading
HM Treasury has published a consultation on the tax deductibility of corporate interest expense in the UK. The consultation has been prompted by the recent publication by the Organisation for Economic Co-operation and Development (“OECD”) of its final Base Erosion and Profit Shifting (“BEPS”) reports, in particular BEPS Action 4,… – Continue reading
Final recommendations about how multinational companies should be allowed to shift profits among different tax jurisdictions were issued this month, and the U.S. Congress has not yet indicated whether it will consider legislation in response to the proposals. Issued by the Organisation for Economic Cooperation and Development (OECD) on October… – Continue reading
Mexico is experiencing a rough time, economically speaking at the moment, but hopes are high for better times ahead. With new tax laws and a relatively young government, these are interesting times for this country. To find out more about how the recent tax reforms will affect Mexico and the… – Continue reading
In a BEPS seminar organised by the Federation of Enterprises in Belgium this week, with a special focus on the practical consequences for Belgian enterprises, a representative of the Belgian Ministry of Finance, Steven Van Elsuwe;, provided more details on the new legislative proposals that have been prepared so far,… – Continue reading
Multinationals have generated big-time revenues with its subsidiaries spread all over the world, which means huge profits and that’s taxable income. In recent years, a number of conglomerates – Amazon, Apple, Google and Starbucks – have engaged in so-called profit-shifting (profit allocation) via transfer pricing methods to pay minuscule taxes…. – Continue reading
(CNS Business): The use of Cayman Islands funds as a wealth management tool for high net worth Latin American families was debated last week at the STEP LatAm Conference in Brazil, where kidnapping is a constant worry for the wealthy and demand for outbound investments is fuelled by privacy and… – Continue reading
Action 13 of the final package of reports issued by the Organisation for Economic Cooperation and Development (OECD) under the base erosion and profit shifting (BEPS) project focuses on a company group’s global value chain and transfer pricing policy, and introduces a standardized three-tiered approach to transfer pricing documentation—core documentation… – Continue reading
The European Commission recently published new rulings, the OECD published its base erosion and profit shifting (BEPS) final reports, and many countries are reviewing and reinforcing their transfer pricing rules—and France is no exception. Tax professionals in France have observed certain recent trends with regards to transfer pricing. The current… – Continue reading
Following the recent Irish budget statement (the “Budget”), the Finance Bill 2015 (the “Bill”) has been published and it implements the changes announced by the Irish Minister for Finance (the “Minister”). The Bill includes additional detail on: the new knowledge development box (“KDB”); and Ireland’s implementation of country by country… – Continue reading
LONDON (Alliance News) – The Renewables Infrastructure Group Ltd on Tuesday said it is planning to raise further funding from its equity placing programme. The company, which invests in renewable energy infrastructure projects, said the fundraising will likely take the form of placing of shares and will be closed in… – Continue reading
The global climate for international tax is rapidly changing. The OECD, the EU and tax authorities around the world have focused attention on tax planning implemented by leading multinational companies. The OECD believes that tax planning and related structures lead to an annual revenue loss of US$100-240 billion. Since 2013,… – Continue reading
On October 5 the OECD published recommended measures that purport to tackle BEPS – Base Erosion Profit Shifting. Exporters around the world need to take note of the latest recommendations of the OECD. Any business that uses overseas agents or warehouses should take note. A company resident in country A… – Continue reading
More than three quarters of UK companies feel their approach to tax planning conflicts with HMRC’s expectations, a new survey has found, as corporates struggle to strike a balance between the needs of investors and tax authorities Law firm Allen & Overy found that 78% UK corporates believe their approach… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) has been leading the charge to improve transparency in tax administration and curb tax avoidance by multinational companies. Endorsed by the G20 nations, including India, OECD recently came out with a package of measures and a road map to tackle base erosion… – Continue reading
The African Union Advisory Board on Corruption (AUABC) recently requested major multinationals operating in Africa to be more open about the taxes and royalties they pay governments to improve transparency and accountability. Although a reasonable request, this is a tall order when you consider that often it is the governments… – Continue reading
On October 22, the United Kingdom’s tax and customs authority announced a public consultation for its proposed modification to its existing patent box regime. The patent box regime is intended to provide incentives for companies that develop patents in the UK and to ensure new and existing patents are further… – Continue reading
MUMBAI: Technologies that are developed in India but their patents registered in tax havens may come under the domestic tax net from the next financial year, when the country is expected to adopt a new world standard aimed at preventing abuse of double taxation avoidance agreements. Many multinational and local… – Continue reading
Introduction The Internal Revenue Service (IRS) recently replaced Revenue Procedure 2006-54 for requesting assistance under the mutual agreement procedure (MAP) article of US tax treaties, and Revenue Procedure 2006-9 for requesting advance pricing agreements (APAs). New Revenue Procedures 2015-40 and 2015-41 largely track draft procedures issued in 2013 (Notices 2013-78… – Continue reading
Major US investor Carl C. Icahn and the Chief Executive Officer of TechNet, Linda Moore, have both recently written letters to leading lawmakers pointing out that the passage of international tax reform by Congress has become a matter of extreme urgency. In his letter, Icahn announced that “the time has… – Continue reading
On 21 October, the European Commission (“EC”) adopted its first decisions in its investigation into Member States’ tax rulings. The investigation, which began in June 2013, has also targeted tax rulings given to Apple and Amazon as well as Belgium’s so-called “excess profits regime”. Although the investigation is conducted under… – Continue reading
The Dutch Secretary for Finance, Eric Wiebes, has reported to the House of Representatives on the impact of the OECD’s base erosion and profit shifting project on Dutch tax rules. His letter, published on the Dutch Government website on October 19 in English, splits measures into those that concern domestic… – Continue reading
Pascal Saint-Amans sups water from a plastic cup, coughing and spluttering. There’s a weariness about him. He’s battling a cold, and is feeling “bloody sick”. The state of his health isn’t terribly surprising given his recent punishing travel schedule. New York last week preceded by Peru, where G20 finance ministers… – Continue reading
Multinational companies (MNCs) in India which have been evading tax on profits created due to a function carried out in the country by shifting contractual risk to some other location may soon find it difficult to escape the domestic tax net. Experts closely working with the government on how to… – Continue reading
“If we do not achieve growth, revenue will not increase. If revenue does not increase, expenditure cannot be expanded.” It is with this statement that the Minister of Finance set the tone of the Medium Term Budget Policy Statement (MTBPS) which he presented on Wednesday against a fiscal backdrop of… – Continue reading
Luxembourg and the Netherlands lost a bit of luster as tax havens for some of the world’s biggest companies this week, as the European Union fired its latest salvo aimed at multinational tax dodging. Yet the Netherlands is on pace to maintain its attractiveness as a tax-friendly address for multinationals,… – Continue reading
