Category: Base Erosion & Profit Shifting

Inland Revenue (Amendment) (No. 6) Ordinance 2018 gazetted

Hong Kong (HKSAR) – The Inland Revenue (Amendment) (No. 6) Ordinance 2018, which primarily implements the minimum standards of the Base Erosion and Profit Shifting (BEPS) package promulgated by the Organisation for Economic Co-operation and Development (OECD) and codifies the transfer pricing principles into the Inland Revenue Ordinance (Cap. 112)… – Continue reading

More Information… More Intense Transfer Pricing Disputes?

The Central Board of Direct Taxes has recently issued guidance on the appropriate use of the ‘Country-by-Country Report’. The CbC filing was introduced as a result of the OECD/G20 Base Erosion and Profit Shifting project. India also introduced the requirement to file CbC reporting recently with the completion of the… – Continue reading

United Arab Emirates: The UAE Tax Environment

The United Arab Emirates has more than 140 free zones across seven emirates, including 20 designated zones with separate laws, regulations and VAT treatment. This can make doing business in the UAE a complex journey. However, there is also the strong benefit of the UAE being one of the easier… – Continue reading

OECD Welcomes Dutch Efforts To Counter BEPS

The OECD has welcomed efforts by the Dutch Government to tackle base erosion and profit shifting but called for the overall tax regime to be simplified, including in area of value-added tax. In its latest Economic Report on the Netherlands, the OECD said that the Government is attempting to change… – Continue reading

Multinationals in New Zealand to pay fair share of tax

WELLINGTON, June 26 (Xinhua) — New measures to ensure multinational companies in New Zealand pay their fair share of tax will come into force next week. Revenue Minister Stuart Nash said the Taxation (Neutralizing Base Erosion and Profit Shifting) Bill, which passed its third reading in Parliament on Tuesday, takes… – Continue reading

OECD Releases First CbC Reporting Peer Reviews

The OECD has released the first peer reviews of the country-by-country (CbC) reporting initiative, reporting that practically all countries that serve as headquarters to large multinationals have introduced new transfer pricing documentation requirements to improve transparency. Country-by-country reporting will see tax administrations worldwide collect and share detailed information on all… – Continue reading

OECD backs BEPS plan in face of critics

The OECD has endorsed New Zealand’s crackdown on multi-national tax evasion, despite significant criticism from local businesses that it departs from OECD standards, Thomas Coughlan reports. David Bradbury, head of the OECD’s tax policy and statistics division, told Newsroom that the OECD was “very pleased with the strong support that… – Continue reading

‘Blacklist Over – But We Must Be Wary Of More Eu Pressure’

SENATOR Dion Foulkes yesterday forecast the country would soon face more pressures from the European Union and should be ready to act quickly to avoid further reputational damage. On Friday, Finance Minister K Peter Turnquest announced the Bahamas had been removed from the European Union’s “blacklist” of non-cooperative jurisdictions for… – Continue reading

Use Eu’s Demands To ‘Set Our Own Table’

The Bahamas must now focus on leveraging the European Union’s (EU) demands to “set our own table” and boost GDP growth and employment, a well-known attorney is urging. Michael Paton, also a former Bahamas Financial Services Board (BFSB) chairman, said this nation has the opportunity to design an “economic substance”… – Continue reading

Ownership Registry Is ‘Not Set In Stone’

Attorney General Carl Bethel QC. Photo: Terrel W Carey/Tribune Staff Legislation to create a central Beneficial Ownership Registry is “not set in stone”, the Attorney General has revealed, with the Government seeking “urgent” consultation on the issue. Carl Bethel QC, addressing a Bahamas Financial Services Board (BFSB)-sponsored seminar, said the… – Continue reading

$1.745m Software Deal To Facilitate Tax Exchange

The Ministry of Finance has embraced a software solution from Vizor AEOI Software to help meet its automatic tax information exchange (AEOI) commitments. The Bahamas will use Vizor’s solution to meet its obligations under the Organisation for Economic Co-Operation and Development (OECD)’s Common Reporting Standard (CRS), and its Foreign Account… – Continue reading

EU to remove two Caribbean countries from blacklist of tax havens

BRUSSELS, Germany (CMC) — Two Caribbean Community (CARICOM) countries are likely to be removed from the European Union list of tax havens next week, when European finance ministers meet here. The Bahamas and St Kitts-Nevis had in the past strongly objected to be included in the list put out by… – Continue reading

Singapore Legislates For IP Tax Concession Reform

Singapore has gazetted a law to repeal the income tax concession for intellectual property income derived by companies benefiting from the Pioneer Service Companies Incentive (PC-S) or the Development and Expansion Incentive (DEI) schemes. The removal of this tax concession was first announced in Singapore’s 2017 Budget at the same… – Continue reading

Malta Ratifies BEPS Convention

Malta has become the latest country to ratify the OECD’s multilateral convention to counter base erosion and profit shifting (BEPS). A notice was published in Legal Notice 142 of 2018 in the territory’s Official Gazette. The Convention, negotiated by more than 100 countries and jurisdictions under a mandate from G20… – Continue reading

Dpm Pledges ‘Most Stringent Controls’ On Ownership Registry

THE Deputy Prime Minister yesterday promised that the proposed Beneficial Ownership registry will have “the most stringent controls”, amid industry concerns over the lack of prior consultation. K P Turnquest told Tribune Business that it was “not an unreasonable guess” to suggest that the Bahamas would follow the Cayman Islands’… – Continue reading

Corporate Taxation Dumped In Eu Bill

The Government has stripped corporate taxation from its anti-blacklisting response, as a top attorney yesterday warned: “Time is not our friend.” Michael Paton, who co-heads the financial sector working group dealing with the European Union (EU) concerns, told Tribune Business it will be “a long summer” as the Bahamas seeks… – Continue reading

UK Revisits Proposed BEPS Changes To Its Double Tax Treaties

The UK tax agency, HM Revenue and Customs, on April 16, 2018, released proposed changes to the list of amendments it intends to make to its bilateral double tax avoidance agreements through the OECD’s base erosion and profit shifting multilateral instrument. The new document – Proposed changes to the provisional… – Continue reading

OECD Releases More Transfer Pricing Country Guides

The OECD has published new transfer pricing country profiles for Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay, bringing the number of such overviews published by the OECD to 44. The profiles explain the current transfer pricing legislation and practices of each country…. – Continue reading

CBDT releases Draft Notification to Amend Income Tax Rules, 1962 [Read Draft Notification]

The Central Board of Direct Taxes ( CBDT ) yesterday released a draft notification which proposes to amend Rule 44E, Form 34C, 34D and 34DA of Income Tax Rules, 1962 as per Base Erosion and Profit Shifting (BEPS) Action Item 5. The proposal has been made with a view to… – Continue reading

Corporate Tax Promise Not ‘Concrete’ For Eu

THE Bahamas will be unable to satisfy the European Union’s (EU) demands by merely promising to implement corporate taxation, a prominent attorney has warned. Michael Paton, who co-heads the financial services industry working group assessing the Government’s ‘blacklisting’ response, told Tribune Business in a recent interview that time and the… – Continue reading

Seychelles Needs To Redouble BEPS Efforts: UN Expert

The Seychelles has been told to deploy more resources to implement recommendations from the OECD on base erosion and profit shifting. Ingela Willfors, a United Nations tax expert from the Swedish Ministry of Finance, held discussions on implementation with the Seychelles’ Minister of Finance, Trade, and Economic Planning and in… – Continue reading

VAT compliance driving digital capabilities in the GCC

Muscat: Tax authorities in the Gulf Cooperation Council (GCC) are starting to use sophisticated digital platforms that require taxpayers to submit data in real time or near-real time prompting companies in the GCC to enhance their digital capabilities. This is changing the way businesses collect, format and report tax information,… – Continue reading

India Adds BEPS Provisions To Qatar Tax Treaty

India has approved amendments to its double tax agreement with Qatar. The amendments update the information exchange provisions between the two countries in line with current international standards. A new Limitation on Benefits (LOB) provision has been introduced, which is designed to prevent “treaty shopping” (whereby companies or transactions are… – Continue reading

Argentina Extends CbC BEPS Reporting Deadline

Argentina’s Federal Administration of Public Income has extended the filing deadline for country-by-country (CbC) notifications. Taxpayers who are part of multinational enterprises now have until May 2, 2018, to file CbC notifications where the ultimate parent company of the multinational group has a December 2017 fiscal year end. The CbC… – Continue reading

TAX TALK: BEPS & ATAD RESHAPING INT’L TAX LANDSCAPE

Speakers corner: Delano asked Raymond Krawczykowski, partner and tax leader at Deloitte Luxembourg, “In your view, what have been the key changes in EU & Luxembourg tax rules in 2017, and what major shifts could be in store for 2018-19?” His response was clear: Beps and Atad. The Base Erosion… – Continue reading

Ibcs Face ‘Much Damage’ Through Blacklisting Bill

THE Bahamas’ ‘blacklisting’ response threatens to “cause a lot of damage” to its IBC business and create “much less certainty” for the financial services industry, a top attorney is warning. Michael Paton, a former Bahamas Financial Services Board (BFSB) chairman, told Tribune Business that the proposed Multinational Entities Reporting Bill… – Continue reading

BEPS Multilateral Instrument To Enter Into Force

The OECD has announced that its multilateral convention to implement tax treaty-related measures to counter base erosion and profit shifting will enter into force on July 1, 2018. The Convention, negotiated by more than 100 countries and jurisdictions under a mandate from G20 Finance Ministers and Central Bank Governors, will… – Continue reading

Corporate Taxation On The Way For Bahamas

The Government’s planned legal reforms pave the way for the introduction of “corporate taxation” on a wide range of Bahamian financial services products, it was revealed yesterday. Carl Bethel QC, the Attorney General, confirmed to Tribune Business that legislation intended to address the European Union’s (EU) ‘blacklisting’ concerns was designed… – Continue reading

Cyprus, UK sign updated double taxation treaty

Cyprus and the UK on Thursday signed an updated agreement on double taxation avoidance on income and capital, which will contribute to further develop commercial and financial relations between the two countries. The agreement, signed in Nicosia by Finance Minister Harris Georgiades and British High Commissioner Matthew Kidd, is based… – Continue reading

Ambassador To Eu Proposal In Wake Of Blacklisting

IN THE aftermath of The Bahamas’ blacklisting by the European Union for being a tax haven, Financial Services Minister Brent Symonette says it might be time for The Bahamas to consider appointing an ambassador to the EU to increase dialogue on matters concerning this country. The St Anne’s MP said… – Continue reading

Indian Master File, First CbC Report Due March 31

The deadline for multinationals to submit a master file and CbC report in India is March 31, 2018, in respect of the 2016-17 financial year. A “master file” must be furnished by multinationals if the total consolidated group revenue exceeds INR5bn and either the aggregate value of international transactions as… – Continue reading

Bahamas ‘Failed To Read Tea Leaves’ On Corporate Tax

THE Bahamas’ failure “to read the tea leaves” and introduce a corporate income tax “for ourselves” has contributed to Europe’s planned ‘blacklisting’, a financial executive argued yesterday. Paul Moss, Dominion Management Services’ president, told Tribune Business that implementing such a tax would mean the European Union (EU) “cannot accuse us… – Continue reading

Last-Ditch Bid To Halt Eu Blacklist

The Deputy Prime Minister and minister of financial services were yesterday travelling to Europe in a last-ditch bid to plead the Bahamas’ case against being ‘backlisted’. Carl Bethel QC, the Attorney General, confirmed to Tribune Business that both K P Turnquest and Brent Symonette are leading a government delegation that… – Continue reading

Egypt To Receive Tax Information Exchange Support

Egypt is to receive international support to implement new measures in the area of tax transparency and information exchange. Unveiled at a meeting on international tax reform in Cairo on March 7, the OECD and Egypt agreed a new project entitled “Enhancing Domestic Resource Mobilization in Egypt through a better… – Continue reading

Mauritius Finalizes CbC Reporting Regulations

Mauritius last month released the Income Tax (Country-by-Country Reporting) Regulations 2018, setting out the jurisdiction’s rules concerning the filing by multinational groups of transfer pricing documentation. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under BEPS Action 13. Under the framework,… – Continue reading

India-Iran DTAA – A Step Forward in India’s Economic Engagement with Central Asia

India and Iran signed a Double Taxation Avoidance Agreement (DTAA) in February, during Iranian President Hassan Rouhani’s official visit to India. The ‘Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income’ aims to encourage the movement of investments and services… – Continue reading

Hong Kong Launches CbC Reporting Portal

Hong Kong’s Inland Revenue Department on March 5 launched its new Country-by-Country Reporting Portal. Groups can now register to file CbC reports for accounting periods beginning between January 1, 2016, and December 31, 2017, using the online portal. The CbC report is one element of a new three-tiered standardized approach… – Continue reading

Gov’t agrees to meet international tax standards

THE GOVERNMENT recently held bilateral talks with the Code of Conduct Group (COCG) to discuss tax transparency and fair taxation in the territory. A press release from the Office of the Premier issued on Tuesday (February 27), said Premier Sharlene Cartwright Robinson and other TCI representatives met with the COCG… – Continue reading

Dutch Cabinet Approves Anti-Evasion Measures

The Government of the Netherlands has announced a comprehensive package of tax anti-avoidance proposals designed to bring the jurisdiction’s rules into line with new European Union anti-avoidance laws and fulfill its obligations under the international BEPS agenda. The plans were detailed in a parliamentary paper sent by State Secretary for… – Continue reading

Barbados Agrees To Phase Out Harmful Tax Regimes

Two Barbados preferential tax regimes have been labelled “potentially harmful” in additional guidance released by the OECD in connection with its base erosion and profit shifting (BEPS) project. The guidance singles out Barbados’s international financial services regime and its credit for foreign currency earnings/credit for overseas projects or services regime…. – Continue reading

Vizor Software Launches CbC Reporting Solution for Tax Authorities

Tax Authorities in jurisdictions who have joined the OECD/G20’s Base Erosion and Profit Shifting (BEPS) inclusive framework can now avail of Vizor’s new Country-by-Country (CbC) Reporting module to fully meet their obligations set out under Action 13. DUBLIN (PRWEB) FEBRUARY 11, 2018 Today, Vizor Software announced the launch of its… – Continue reading

Bermuda Lists CbC Report Exchange Partners

The Bermuda Government on January 31, 2018, updated the lists of the countries with which it will exchange country-by-country reports filed in Bermuda in 2018 and in 2019. The Government has disclosed that it expects to exchange CbC reports with a total of 41 territories in 2018 relating to financial… – Continue reading

Costa Rica Gazettes Country-By-Country Reporting Rules

On February 2, 2018, Costa Rica published Resolution no. DGT-R-001-2018 in its Official Gazette, setting out the rules for filing a country-by-country report. The parent company of a multinational group resident in Costa Rica with consolidated group revenue of the equivalent of EUR750m in the Costa Rican currency – presently… – Continue reading

Spain Publishes 2018 Tax Compliance Plan

The Spanish tax authority has published its annual tax and customs control plan for 2018, which details the tax compliance and enforcement measures that it intends to undertake in the coming year. The plan, published by the tax authority on January 23, features four key pillars: preventative measures, including a… – Continue reading