Japan’s Ministry of Finance said international policy veteran Masatsugu Asakawa will become the country’s top financial diplomat, whose tasks include co-ordinating with other nations and the IMF as well as arranging currency interventions. Asakawa’s broad network with policymakers both inside and outside Japan puts him in an ideal position to… – Continue reading
Agreement with Mauritius to be renegotiated. National Treasury says the abuse of double tax agreements by multinational companies is the main reason why the agreement with Mauritius has been renegotiated. National Treasury head of tax and financial sector policy Ismail Momoniat says companies have often used dual tax residence structures… – Continue reading
The FINANCIAL — Tax is firmly under the spotlight and in the global insurance industry, the ramifications for finance and tax teams will be felt in both a new set of business demands and an overhaul of how these functions interact and operate. However, a new report from PwC says… – Continue reading
NEW YORK – When it comes to funding development, taxes are perhaps the most critical piece of the puzzle. But the system of taxing global profits is broken – and it is exacerbating inequality both within and across countries. If the world is to make progress toward its goals of… – Continue reading
Industrial & Manufacturing groups which have operations in Finland, should review their funding arrangements to ensure they remain tax effective following a recent case in Finland which may now be put on a statutory footing. The Finish tax authorities treated a hybrid instrument as equity and the related interest expense… – Continue reading
Oxfam, a multinational organisation, says Africa is haemorrhaging billions of dollars because multinational companies are cheating African governments out of vital revenues by not paying their fair share in taxes. This is contained in a statement issued by the organisation, interested in combating poverty, and made available to newsmen in… – Continue reading
Access to company data is vital if policymakers are to understand how changing regulatory requirements influence performance Much focus has recently fallen on the issue of tax avoidance, as research on the subject has increasingly shown that the global economy is losing out on billions of dollars to a byzantine… – Continue reading
The MoU is designed to give some insight into the process that will be adopted by the fiscal authorities of the two countries when assessing the tax residence of a ‘person’. International investors including South African businesses already use Mauritius as their base for their growth on the continent, but… – Continue reading
On 12 June 2015, Insurance Europe published its comments on the permanent establishment (PE) status aspects of the draft Base Erosion and Profit Shifting Action Plan (published by the Organisation for Economic Cooperation and Development (OECD) in May 2015). The draft Action Plan aims to address weakness in the international… – Continue reading
On June 8th 2015, the OECD released a new package of measures for the implementation of a new Country-by-Country (CbC) reporting plan developed under the OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS) Project, aimed at improving transparency in international tax matters. The CbC reporting plan was founded… – Continue reading
Georgia’s capital Tbilisi will host dozens of top officials including members of the G20 at a special meeting in October to discuss tax avoidance strategies on national tax bases. A group of delegates from 30 countries from Eastern Europe, Central Asia and the EU are due to take part in… – Continue reading
Ireland’s attractively low rate of corporate taxation is once again under pressure with the recent release of the European Commission’s new action plan to tackle tax avoidance. The commission has been prompted into this politically ambitious move by public outcry over big, usually American, companies avoiding tax in the EU…. – Continue reading
OECD and G20 Action Plan on Base Erosion and Profit Shifting (BEPS) was adopted in 2013. It consists of 15 actions including transfer pricing, taxation of controlled foreign corporations (CFC), digital commerce, hybrid instruments, international information exchange, tax treaty shopping etc. In 2013, OECD working group prepared draft documents regarding… – Continue reading
Action 3 of the OECD’s Base Erosion and Profit Shifting (BEPS) agenda promised to address how countries could use controlled foreign corporation (CFC) rules to combat BEPS. Unfortunately (or fortunately, depending upon one’s vantage point), as is pretty much universally agreed, the OECD’s draft report on CFC rules (the “draft”)1… – Continue reading
The German government has announced plans to incorporate Action 13 (guidance on transfer pricing documentation and country¬by¬country (CbC) reporting) of the OECD’s BEPS project into local legislation. The wording of the new law is being drafted and may be published some time in autumn of this year. It is the… – Continue reading
OECD common reporting standard On 3 June 2015, the Treasurer announced that Australia had signed the Organisation for Economic Co-operation and Development’s (OECD) common reporting standard (CRS) Multilateral Competent Authority Agreement which enables automatic exchange of CRS information between countries. Australia proposes to implement the CRS from 1 January 2017,… – Continue reading
The European Commission has released a working paper that looks at how significant the introduction of the modified nexus approach will be for the tax affairs of multinational companies that use patent box regimes Entitled Patent Boxes Design, Patents Location, and Local R&D, the paper suggests “that in the majority… – Continue reading
Ahead of Dublin visit, health expert discusses fighting poverty and sharing prosperity. “The Koreans have a saying that you bury your spouse in the ground but you bury your children in your heart,” said Dr Jim Yong Kim. The Korean-born health expert is speaking to The Irish Times at his… – Continue reading
A new treaty makes it more difficult for companies to take advantage of tax loopholes to avoid their financial obligations. Globally, initiatives are afoot to close tax loopholes and South Africa is one of the frontrunners – its new treaty with Mauritius removes the allure for tax-shy corporates doing business… – Continue reading
DUBAI: This week the UK’s National Crime Agency (NCA) published their 2015 National Strategic Assessment. The Assessment presents a comprehensive picture of the threat to the UK from serious and organised crime, and helps to inform the work of the NCA and their international partners, including in the UAE. Some… – Continue reading
The biggest hurdle to stopping multinational tax evasion isn’t the companies themselves. It’s the governments behind them. As the OECD works swiftly on its plan to stop multinational tax evasion, the United States has already signalled it’s not happy with what’s being proposed. The US has always been clear on… – Continue reading
The verities of international tax law are no more. The days of strong residence-based rules of corporate taxation are numbered. The age of the Permanent Establishment (“PE”) as the central concept of international tax is drawing to a close. That seems to be the message from the OECD International Tax… – Continue reading
Executive summary On 8 June 2015, the Presidency of the EU Council (Latvia) sent a report (The Report) to the Permanent Representatives Committee and the European Council. The Report sets out the current state, as well as a number of open issues and questions, in regard to the 18 March… – Continue reading
The Government of Netherlands has successfully negotiated the inclusion of anti-abuse provisions, aimed at combating cross-border tax avoidance, in tax treaties with Ethiopia, Ghana, Kenya, Malawi, and Zambia. At present, talks are being held with another seven countries and new agreements with several other countries are expected to be concluded… – Continue reading
Conor Hynes and Ronan Connaughton of Deloitte Ireland explore the impending changes arising from BEPS Action 7 and the Skandia case and provide insight on the potential tax impact for the insurance industry. The Greek philosopher Heraclitus is attributed with the saying, “the only thing that is constant is change”…. – Continue reading
Before going after multinationals that channel profits through tax havens and low-tax nations, you must define what one is, business lobbies have told the Abbott government. Treasurer Joe Hockey announced in the May budget that the government would be strengthening anti-avoidance laws to go after 30 companies with over $1… – Continue reading
Companies registering their intellectual property in Israel will be charged only 5% tax on dividends. The committee considering changes in the Law for the Encouragement of Capital Investments, headed by former Ministry of Finance director general Yael Andorn, is recommending extension of the tax break granted under the law to… – Continue reading
The United States has been criticized on more than one occasion for failing to be a meaningful participant in the OECD’s multi-pronged initiative to address base erosion and profit shifting (BEPS). Some commentators have even gone so far as to accuse the United States of actively working against the BEPS… – Continue reading
Pretoria — Government has gazetted the South Africa-Mauritius tax treaty which came into force at the end of May, said National Treasury. “This new treaty reflects changes in the tax policies of the two countries and is in line with international best practices to deal with tax abuse as outlined… – Continue reading
International tax rules will soon change, but companies’ behaviour may change sooner. There will soon be fewer places for multinational companies and ultra-rich individuals to squirrel away money. In November leaders of the G20 are expected to adopt a full range of measures to curb the practices of base erosion… – Continue reading
The reported resurgence of cross-border mergers involving US companies that then move their corporate headquarters abroad shows that anti-tax avoidance measures passed last year were “a sticking plaster rather than a long-term solution”, an expert has said17 Jun 2015 The Financial Times reported (registration required) that demand for corporate ‘inversion’… – Continue reading
The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners should be aware of the potential impact those changes can have on their existing inbound U.S. structures…. – Continue reading
Bring together an impressive group of respected tax professionals from all over Africa, International Bureau of Fiscal Documentation (IBFD) is set to hold “Africa Tax Symposium, Trends in International Taxation: An African Perspective,” from June 18-19, 2015 in Livingstone, Zambia. IBFD announces that its inaugural The two-day event will present… – Continue reading
The United States is through trying to needle the OECD’s base erosion and profit-shifting project with pinpricks. Last week, Robert Stack, U.S. Treasury deputy assistant secretary (international tax affairs), abandoned the subtle digs Treasury had been using to attack BEPS and flat-out said the United States is extremely disappointed in… – Continue reading
As the financial world continues its march towards a more transparent and open environment, regulations governing private wealth are under scrutiny. The traditional is changing for good while new players emerge. Once was a time, not too long ago, the words “Swiss bank” conjured up evocative imagery: secret deals; bank… – Continue reading
The LuxLeaks financial scandal, which entailed disclosure by the International Consortium of Investigative Journalists of tax rulings, galvanized public opinion and gave rise to the creation of TAXE, the European Parliament’s special committee on tax rulings. This article explains why TAXE was created and shares with you highlights from the… – Continue reading
Senior Republicans voice concerns over Obama administration’s response to plan Political divisions are opening up in Washington over the US response to the overhaul of international tax rules by the global powers, an initiative with big implications for Ireland’s corporate tax regime. The Republican leaders of the two tax-writing committees… – Continue reading
Transfer pricing has emerged as a key focus area both globally and locally. From an international scene, the OECD/G20 venture — a club of advanced countries in Europe and North America, has been working on action plans to help tax administrations deal with Base Erosion and Profit Shifting (BEPS) project…. – Continue reading
On May 24, Premier Li Keqiang and a delegation of Chinese senior officials arrived in Chile. During the visit, China and Chile signed a double taxation avoidance agreement (DTA), updated their Free Trade Agreement and agreed on setting up an RMB clearing center in Chile, reports China Briefing. China and… – Continue reading
Speaking at the Insurance Day 2015 Summit on 10 June 2015, Minister of Finance Bob Richards told attendees that “the more we drive home that the insurance sector in Bermuda is not a stereotypical tax haven gimmick to key onshore decision makers the less the threat from IRS and other… – Continue reading
Dirty money resulting from crime, corruption and tax evasion is estimated to cost over one trillion dollars every year. It exacerbates poverty and inequality, and should be regarded as one of the most pressing issues globally. An Oxfam report found that G7-based companies and investors cheat Africa out of tens… – Continue reading
Sydney, 10 June (Argus) — The Australian government has released legislation to tighten rules governing corporate taxation such as the use of offshore tax havens. The bill is not aimed at any particular sector of the economy, but several resource and commodity companies have come under scrutiny following a Senate… – Continue reading
Heads of state meeting at the G7 Summit in Bavaria, Germany committed to promoting automatic exchange of tax information and tax rulings to discourage multinational companies from shifting profits from country to country to avoid taxes, reports Accounting Today. In a joint declaration, the G7 leaders reaffirmed their commitment to… – Continue reading
The Argentine Supreme Court ruling on Toepfer International, a commodity exporting firm, has finally been published, tw o months after the decision, providing lessons for BEPS action 10 (cross border commodity transactions). This case, AFIP v Alfred C Toepfer Internacional, belongs to the first group of three controversies, related to… – Continue reading
Demands for greater transparency from business about their tax affairs have prompted more than half of all FTSE 100 companies to disclose information about their approach to taxation, compared with less than a third two years ago, reports the Financial Times. The rise in disclosures is a sign of the… – Continue reading
08/06/2015 – Pushing forward efforts to boost transparency in international tax matters, the OECD today released a package of measures for the implementation of a new Country-by-Country Reporting plan developed under the OECD/G20 BEPS Project. The Country-by-Country Reporting Implementation Package will facilitate a consistent and swift implementation of new transfer… – Continue reading
OVERSEAS investment by Thai companies has been surging in recent years and this trend is almost certain to continue. One of the questions frequently asked by Thai investors when seeking to acquire foreign operating companies or establish overseas subsidiaries is what type of funding structure would be the most tax… – Continue reading
OECD propose country-by-country reports on their financial affairs Proposed new obligations on multinationals to produce country-by-country reports on their financial affairs will have a “massive impact” on them, a leading member of the Organisation for Economic Development and Cooperation has said. Pascal Saint-Amans , director of the Center for Tax… – Continue reading
Australia should consider adopting tax structures like those used in Ireland and Luxembourg in order to attract greater foreign investment, the government’s tax advisory body has recommended. On Thursday night, Assistant Treasurer Josh Frydenberg released several reports by the Board of Tax, which advises the government on how to reform… – Continue reading
Tax administrators would be allowed to use hindsight to evaluate the appropriateness of transfer-pricing decisions made by companies in transactions involving hard-to-value intangible assets under an approach proposed by the Organisation for Economic Co-operation and Development (OECD) on Thursday. The OECD’s discussion draft looks at the issue of arm’s-length pricing… – Continue reading
