It may be time for another letter from Tom Cotton. Cotton, the Republican senator from Arkansas, had been in office only a few weeks back in March when he got 46 senators to sign on to an open letter to the leadership of Iran. The letter pointed out that agreements… – Continue reading
Bold step on non-resident levy likely to be first of many. A tax policy paper released yesterday proposes changes on the taxation of non-residents in respect of New Zealand-sourced interest income. These changes, if implemented, will affect large multinationals, banks and even individual New Zealand borrowers. As the first significant… – Continue reading
CFOs of multinational corporations have mixed reactions to the Organization of Economic Cooperation and Development’s crackdown on base erosion and profit shifting by global companies, according to a new survey. The survey, by the tax advisory business Taxand, found that multinational CFOs are split 52 percent (agree) versus 48 percent… – Continue reading
Major G20 tax event in Istanbul hears claims that fighting tax scams is ‘vital issue’ for developing nations ISTANBUL Fighting tax evasion is like fighting international terror, Turkey’s finance minister has claimed. Mehmet Simsek was speaking at an international G20 tax event in Istanbul on Thursday where he said that… – Continue reading
The Government and the IRD are moving to crack-down on the big banks, overseas customers, and other offshore-owned entities that are not believed to be paying their fair whack of New Zealand tax. The IRD’s produced a 46 page issues paper making suggestions for new rules that would tighten up… – Continue reading
The deductibility of interest has for years been a contentious issue and this has been reaffirmed with the introduction of section 23M into the Income Tax Act No 58 of 1962 (the “Act”) with effect from 1 January 2015. A further addition to the interest sphere of income tax is… – Continue reading
It’s a race against time for governments of the worlds’ largest economies seeking a coordinated plan to make it more difficult for multinational corporations to shield profits overseas. Some countries are preparing to act on their own. International finance leaders from advanced- and developing- economies are set to gather Wednesday… – Continue reading
In the 2015 Budget Speech presented to the National Assembly on 25 February 2015 the Minister of Finance announced that amendments will be proposed to change the rules for the digital economy in line with the latest guidance issued by the Organisation for Economic Co-operation and Development (“OECD”) in its… – Continue reading
The Davis Tax Committee (“DTC”) recently addressed the issue of base erosion and profit shifting (“BEPS”) in South Africa. The international importance of transfer pricing was once again emphasized when 4 out of the 15 actions identified in the OECD Action Plan on BEPS related to transfer pricing. The 15… – Continue reading
The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project is changing the international tax landscape by building a new international consensus on how to tackle BEPS. In September 2014, the first seven of the deliverables under the 15-point BEPS Action Plan were presented to G20 Finance Ministers when they met… – Continue reading
Introduction The Organisation for Economic Cooperation and Development (OECD) recently issued a discussion draft on the use of profit split methods in relation to transfer pricing and in the context of global value chains as part of the Base Erosion and Profit Shifting (BEPS) project.(1) This update provides an overview… – Continue reading
As compared to past federal Budgets, Budget 2015 contained fewer (and arguably less controversial) international tax measures. Nevertheless, Budget 2015 did announce the Government’s intention to address taxpayer concerns relating to (i) the withholding obligations borne by non-resident employers that have non-resident employees that work in Canada, and (ii) the… – Continue reading
THE global economic recovery, which has been assessed as uneven with manifest divergences across countries and regions, has however, been supported by Emerging Markets and Developing Countries (EMDCs) as the major drivers of global growth, although it is currently moderating in some countries. But the Intergovernmental Group of Twenty-Four on… – Continue reading
Turkey is to host a G20 international tax symposium next month to discuss developments to address Base Erosion and Profit Shifting (BEPS) and the exchange of information between tax administrations The event, organised by Turkish Ministry of Finance, also aims to ensure that developing and low-income countries benefit from the… – Continue reading
The April 21, 2015 Federal budget released by the Conservative Government includes updates on Canada’s involvement in the BEPS project and how Canada intends to fulfill its obligations to implement an automatic exchange of tax information with the G-20. Notably (with the exception of the common reporting standard discussed below),… – Continue reading
Ireland found itself surrounded by supporters, for the first time, on the issue of corporate tax rates, during an informal meeting of EU finance ministers, reports the Irish Examiner. Finance Minister Michael Noonan was not present, as he returned to Dublin early, but the head of the Central Bank, Patrick… – Continue reading
An OECD initiative on tax evasion is causing ripples around the world While a host of topics — from the necessity and the proposed scope of corporate tax reform, to corporate rate reduction and corporate inversions — are of major concern to those engaged in international tax, the overriding issue… – Continue reading
On Saturday 25 April, at the second session of the informal meeting of the Economic and Financial Affairs Council (ECOFIN), one of most important issues on the agenda was the further development of the Capital Markets Union concept, which was broadly supported by the ministers and Governors of central banks…. – Continue reading
The Luxembourg Intellectual Property (IP) tax regime will be aligned to the “modified nexus approach”, as per Pierre Gramegna, Luxembourg’s Finance Minister. The IP regime is expected to be modified in 2015 and to be in force no later than 30 June 2016. This is driven by the OECD’s Base… – Continue reading
Multinationals play such a large role in many nations’ budgets that effective control is crucial. Business Tax-base erosion cripples Africa 24 Apr 2015 00:00 Lisa Steyn Multinationals play such a large role in many nations’ budgets that effective control is crucial. Finance Minister Nhlanhla Nene says practices such as incorrect… – Continue reading
Registration is open for the Organisation for Economic Co-operation and Development’s (OECD’s) latest webcast, which will update stakeholders on progress towards the conclusion of its base erosion and profit shifting (BEPS) work. The webcast will last for one hour on June 8, 2015, beginning at 15:00 Central European Time (CET)… – Continue reading
The Minister of Finance (Canada), the Honourable Joe Oliver, presented the Government of Canada’s 2015 Federal Budget (“Budget 2015”) on April 21, 2015 (“Budget Day”). Budget 2015 contains several significant proposals to amend the Income Tax Act (Canada) (the “ITA”) while also providing updates on previously announced tax measures and… – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading
Finance Minister Arun Jaitley has sought urgent implementation of common reporting standards on automatic exchange of information globally, asserting that it is the only way to tackle the challenges posed by black money and stop tax evasion. The problem of offshore tax evasion and flow of illicit money can be… – Continue reading
OECD director admits UK’s Google tax may undermine some of the body’s BEPS work GOVERNMENT plans to introduce a diverted profits tax have caused embarrassment at the OECD, according to Pascal Saint-Amans [pictured], the body’s director leading the Base Erosion and Profit-Shifting (BEPS) project. Appearing via video link before Australia’s… – Continue reading
Draft plans to remove tax benefits for cross-border funds to eradicate Base Erosion and Profit Sharing could significantly impact investment into Ucits, the Alfi conferences hears. New draft OECD rules designed to combat Base Erosion and Profit Sharing (Beps) could have dire unintended consequences for cross-border funds, warned Roger Exwood,… – Continue reading
Law360, New York (April 06, 2015, 3:10 PM ET) — A draft report released Friday by the Organization for Economic Cooperation and Development on strengthening controlled foreign-company rules to crack down on tax evasion said there are substantial disagreements among member states about how to best define CFC income. The… – Continue reading
National tax laws are struggling to keep pace with the rise of the digital economy and the progress of multinational companies. These factors leave gaps that are susceptible to misuse and lead to cases of double non-taxation, which undermine the integrity and fairness of tax systems around the world. The… – Continue reading
The likely centrepiece of Treasurer Joe Hockey’s assault on multinational profit-shifting – a so-called “Google tax” – risks breaking Australia’s international tax treaties, the Parliamentary Budget Office has found. The independent adviser warned that the unilateral introduction of a “diverted profits tax” like ones being considered by Australia and Britain… – Continue reading
AS PART of its Base Erosion and Profit Shifting (BEPS) project, the OECD has launched a public consultation on Action 12 – the mandatory disclosure of tax avoidance strategies by multinational companies. The 83-page draft document provides examples of various disclosure regimes in place in member countries, setting out recommendations… – Continue reading
Summary:A new discussion paper released by the Australian government suggests that the emergence of new financial transaction technology such as bitcoin is making it tough for the country’s authorities to clamp down on tax avoidance. The emergence of new technology is proving to be problematic for Australia’s tax system, according… – Continue reading
This article continues our series on the Base Erosion and Profit Shifting (BEPS) project, and the Action Plans that have so far been submitted, by the Organisation for Economic Co-operation and Development (OECD). We now look at Action Plan 15 on Developing a Multilateral Instrument to Modify Bilateral Tax Treaties…. – Continue reading
ISLAMABAD: A three member high level delegation of Inland Revenue-Policy Wing of the Federal Board of Revenue (FBR) will attend a three day conference on regional taxation problems in the first week of April in Japanese capital Tokyo. The conference is funded by the International Monetary Fund (IMF) as well… – Continue reading
The Abbott Government will shortly release a discussion paper on the Australian tax system. It will be the first step towards the much anticipated tax white paper. International factors should figure prominently in the white paper — specifically, how to ensure that Australia has a resilient tax system given the… – Continue reading
(CS) The Lord Mayor of the City of London was in Luxembourg Tuesday to meet with representatives of the financial sector and political decision-makers to discuss a number of issues, from BEPS to FTT and TTIP. Speaking to the press on Tuesday, Alan Yarrow explained that there is much common… – Continue reading
President Barack Obama’s proposal to impose a minimum tax on the foreign income of US companies would place them at a substantial competitive disadvantage in global markets, Pamela Olson, former assistant secretary for tax policy at the US Department of Treasury, has said. As well as including proposals for a… – Continue reading
WASHINGTON – The Senate voted Tuesday to reject a proposal by Sen. Bernie Sanders, I-Vt., that would have created millions of infrastructure jobs and closed an “absurd” tax loophole to pay for the plan. Fifty-two lawmakers opposed the proposal during votes on amendments to a GOP fiscal 2016 budget proposal…. – Continue reading
Internationally, Australia has been seeking to take a lead on addressing transfer pricing issues as chair of G20, with a focus on a global and coordinated approach to base erosion and profit shifting (BEPS). Domestically, the focus has been on reform of the transfer pricing regime in light of deficiencies… – Continue reading
Earlier today the UK government delivered its last budget before the UK general election in May. Many of the measures were, as one might expect so close to an election, focused on personal rather than corporate taxation. However, below is a summary of some of the business related announcements: Diverted… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) has briefed leaders of the Group of Twenty (G-20) nations on recent advances towards the conclusion of its base erosion and profit shifting project, which it says may be completed ahead of schedule. The OECD presented a report to the G-20 Finance… – Continue reading
BARBADOS IS IN A “good position” to thrive as an international financial centre (IFC) despite various challenges, including a worrying initiative introduced by the Organisation for Economic Cooperation and Development (OECD). Ben Arrindell, one of the island’s leading international business practitioners who has also advised Government on such issues or… – Continue reading
Last week, we discussed the revised set of standards for Transfer Pricing (TP) documentation and a template for country-by-country reporting (CBCR) of income, earnings, taxes paid and certain measures of economic activity as contained in Action Plan 13 of the Base Erosion and Profit Shifting (BEPS) Project. The CBCR provides… – Continue reading
Mainland authorities are targeting tax evasion by multinationals, implementing new regulations aimed at “unreasonable” payments such as for service and royalties to overseas related parties. “The tax administration’s nationwide audit has discovered instances of multinationals in China making unreasonable payments to related parties overseas, causing the erosion of our tax… – Continue reading
It’s been dubbed the ‘Google tax’! Starting April 1st, the UK will levy a new ‘diverted profits tax’. This is the British government’s offensive against multinationals like Google, Amazon, Starbucks and others accused of shifting profits and avoiding tax. In doing so UK will become the first country to implement… – Continue reading
On March 18, 2015, the European Commission presented a package of transparency measures aimed at tackling corporate tax avoidance and harmful tax competition within the European Union, reports Tax News. The transparency package is said to be “the first step in the Commission’s ambitious agenda for 2015 to fight tax… – Continue reading
Tough tax disclosure laws introduced by the former Labor Government represent “an invasion of privacy and intrusion for Australian private companies,” Prime Minister Tony Abbott has said. Abbott made the comment during a joint press conference with the Assistant Treasurer Josh Frydenberg. The press conference followed a meeting of the… – Continue reading
While the problems with our international tax system are complex, the solution is relatively simple: U.S. corporations should pay the same tax rate, at the same time, on their domestic and foreign profits. The ranking member of the Senate Finance Committee, Sen. Ron Wyden, made the case for this reform… – Continue reading
Transfer pricing activities have faced increased scrutiny by tax authorities around the world and within the United States. As such, many companies are seeking more guidance on how to best manage their transfer pricing life cycle. The life cycle consists of four phases, which include planning, implementation, documentation and monitoring…. – Continue reading
The measure The Chancellor confirmed that the new diverted profits tax (DPT) will be introduced from 1 April 2015. DPT will apply in two distinct situations, being: Where a foreign company has artificially avoided having a taxable presence in the UK; and Where a UK company (or a UK permanent… – Continue reading
The OECD’s base erosion and profit-shifting project has dominated the international tax scene for over a year. Ever since the G-20 tasked the organization with finding solutions to the perceived problem of multinationals paying low effective tax rates, the international tax community has talked about little else. The OECD hoped… – Continue reading
