Category: Base Erosion & Profit Shifting

I-T officials strive to get rid of ‘tax terrorists’ tag

Vivek Prasad, chief commissioner of Income-Tax – III, Mumbai said they were striving to rid themselves of the unwarranted epithet of ‘tax terrorists,’ and said with regards to tax morality, base erosion, profit shifting and GAAR (general anti-avoidance rules) they were on a learning curve and are evolving beyond the… – Continue reading

Nations may come together to stop abuse of tax pacts

NEW DELHI: India’s attempts to amend tax treaties with countries such as Mauritius may have drawn a blank so far, but its efforts are about to get a huge boost with several nations getting together to ramp up work on a global convention to plug treaty abuse. “Multilateral convention will… – Continue reading

G20 leaders in the mood to act on tax avoidance after Luxembourg leaks

Ahead of next weekend’s G20 summit, the release of leaked documents showing Luxembourg’s facilitation of industrial scale tax avoidance by multinational corporations could not have been better timed. A cache of documents obtained by the International Consortium of Investigative Journalists, and released on Thursday, found hundreds of companies – including… – Continue reading

Luxembourg leaks: G20 alone can’t stamp out tax avoidance

The hollowing out of tax collected for public purposes by rich and poor nations is not confined to technology and mining companies, according to a major leak of secret tax agreements covering more than 340 companies around the world. The documents, published by the International Consortium of Investigative Journalists, include… – Continue reading

Global base erosion rules likely to be finalised by end 2015NEW DELHI:

The global base erosion and profit shifting (BEPS) rules, aimed at collecting a fair share of taxes from multinationals operating in different tax jurisdictions, are likely to be finalised by December 2015, a senior finance ministry official today said. “Work on BEPS is moving very fast. If things go on… – Continue reading

Tax Office goes hard in pursuit of tax lost to ‘aggressive planning’

Tax Commissioner Chris Jordan has rapidly abandoned several agreements with multinationals aimed at giving companies certainty about the tax they are required to pay in Australia in future years, after deeming they had misled and engaged in “aggressive tax planning”. Taxpayers can enter into a deal to lock in the… – Continue reading

Medical supplies group used Irish firm in tax deal

Covidien transferred right to $6.9bn loan to new entity Multinational medical supplies group, Covidien, transferred the right to loans totalling $6.9 billion from Luxembourg to a new Irish company as part of an elaborate inter-group tax planning arrangement agreed with the Luxembourg tax authorities in 2009. Under the deal, the… – Continue reading


From 1970 to 2011, US$2 trillion from Latin America and the Caribbean have been funneled to offshore tax havens. It’s money that moves behind the scenes, in illicit financial flows (IFF). These transnational transfers come from three sources of illegal funds: corruption (bribery), money laundering (contraband, trafficking of drugs, weapons,… – Continue reading

G20 committed to global response to deal with cross border tax evasion: India

New Delhi: As it attempts to unearth black money stashed abroad, India today said the Grouping of 20 major economies(G20) of which it is a member is committed to a global response to deal with cross border tax avoidance and evasion. Tax evasion will be a key issue at G20’s… – Continue reading

Dutch tax regime similar to Luxembourg’s, auditors find

BRUSSELS – Dividend, interest and royalty payments that companies let pass through the Netherlands to avoid taxation have increased substantially in the past decade, the Netherlands Court of Audit has found. In a report published on Thursday (6 November), the court writes that tax laws and treaties that originally were… – Continue reading

Singapore: Changing Expectations on Transfer Pricing Documentation

Ernst & Young Solutions LLP, Singapore* It has been eight years since the Inland Revenue Authority of Singapore (IRAS) first released its Circular on Transfer Pricing Guidelines. During that time, there have been significant changes in the international tax landscape. In Singapore, we have seen supplementary guidance from the IRAS… – Continue reading

Big 4 Audit Firms Play Big Role in Offshore Murk

For more than a decade, tax gurus at PricewaterhouseCoopers helped Caterpillar Inc., the U.S. heavy equipment maker, move profits produced by its lucrative spare-parts business from the U.S. to a tiny subsidiary in Switzerland. Little changed except the bookkeeping. Parts were still shipped from suppliers to a warehouse in Morton,… – Continue reading

OECD: “permanent establishment” definition should be changed to prevent profit shifting by companies

Tax treaty rules on ‘permanent establishment’ should be changed in order to ensure companies are taxed in the jurisdiction where their economic activity takes place, the Organisation for Economic Cooperation and Development (OECD) has said.05 Nov 2014 Corporate tax Tax Tax Disputes and Investigations TMT Advanced Manufacturing & Technology Services… – Continue reading

ICC warns enhanced tax dispute resolution mechanism needed to prevent exacerbating double taxation

ICC has expressed concern that the Organization for Economic Co-operation and Development (OECD) Action Plan on combating Base Erosion and Profit Shifting (“BEPS”), mandated by the G20, may inadvertently incur severe collateral damage on compliant taxpaying companies of all sizes as a result of well-meaning measures undertaken unilaterally by states… – Continue reading

What will define success at the Brisbane G20 Summit?

It is important that the Brisbane G20 Summit on Nov. 15–16 is a success. In an increasingly integrated global economy, effective forums for economic cooperation are needed. The 2008 global financial crisis was the catalyst for the G20 becoming a leaders’-level forum. The Washington, London, and Pittsburgh summits helped save… – Continue reading

OECD – Low value-adding intra-group services (BEPS Action 10)

November 3: The Organisation for Economic Cooperation and Development today released a discussion draft of the proposed modifications to Chapter VII of the OECD Transfer Pricing Guidelines relating to low value-adding intra-group services. Action 10 of the OECD’s action plan on base erosion and profit shifting (BEPS) directs the OECD… – Continue reading

Developing nations lose $100bn in tax revenue each year – will G20 reforms help?

Global tax reform is on the agenda at the G20 in Brisbane to prevent aggressive tax avoidance, but developing countries are being excluded from decision-making Tax avoidance and evasion will be at the top of the agenda at the G20 Leaders’ Summit this month, when the leaders of many of… – Continue reading

beps offshore investments ireland oecd uk USA inversion tax planning

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email to buy additional rights. It is no secret that Apple, Starbucks and Amazon are among several high-profile companies… – Continue reading

Transfer pricing inflicting heavy losses

HA NOI (VNS) — Appropriate policies and enhanced management capacity are critical in the fight against transfer pricing to ensure a healthy business investment environment in Viet Nam, said experts on Wednesday. They were participating in an online discussion on the Government’s e-portal. Transfer pricing is causing losses to the… – Continue reading

Bruton To Promote Irish Corporate Tax Changes In US

Ireland’s Enterprise Minister Richard Bruton is undertaking his first investment mission since the Government announced major changes to the corporate tax regime as part of Budget 2015. Bruton is visiting the East Coast of the US as part of a program of engagement by the Government with multinational companies on… – Continue reading

HMRC investigators home in on massive Square Mile tax avoidance scheme

European prosecutors and tax authorities are intensifying an investigation into a huge tax avoidance trading scheme costing European countries hundreds of millions of euros. The investigation centres on complex stock trades that major banks allegedly use to earn tax rebates. The practice was revealed by the Bureau three years ago…. – Continue reading

NZ to join global crackdown on tax evasion

Revenue Minister Todd McClay today announced New Zealand’s timetable for participation in a global automatic exchange of information aimed at cracking down on tax evasion. G20 leaders announced the initiative in September 2013 – and in May 2014, New Zealand, along with all OECD countries, joined in the general declaration… – Continue reading

Countries and Companies Join OECD BEPS Train

The OECD’s Action Plan on BEPS was published in July 2013 to reform the international tax system. The Action Plan identified 15 Actions to address BEPS. Seven of the 15 Action Plan items are now moving out of the station. I. Introduction On September 16, 2014 the OECD, together with… – Continue reading

New Report On BEPS Project Impact For Life Sciences Companies

Multinational life sciences companies should review their organizational structures and perform scenario planning to assess the likely impacts of the Organisation for Economic Co-operation and Development’s (OECD’s) Action Plan on Base Erosion and Profit Shifting (BEPS), says a new report from KPMG. “The Post Base Erosion and Profit Shifting World”… – Continue reading

Bloomberg BNA and Tax Analysts Interview Elan Keller on OECD Forum Tax Chiefs’ Pledge for Greater Cross-Border Cooperation

NEW YORK, Oct. 27, 2014 /PRNewswire/ — Bloomberg BNA’s International Tax Monitor and Tax Analysts interviewed Caplin & Drysdale’s Elan P. Keller concerning a pledge made at the 2014 OECD Forum on Tax Administration (FTA) by tax chiefs from 38 countries to invest in resources to implement a new standard… – Continue reading

Tax justice group exposes corporate tax dodgers

Green Left Weekly and ActionAid will be co-sponsoring a Political Economy Society seminar at Sydney University on October 29 to discuss the case for greater international efforts to combat corporate tax avoidance before the G20 summit. Large corporations systematically avoid paying the statutory level of company tax — a low… – Continue reading

Government is considering interest deduction restrictions for infrastructure

Officials from the Treasury and HM Revenue and Customs (HMRC) have been meeting with representatives of the PPP/ PFI industry to discuss the implications for infrastructure projects of possible restrictions to interest relief.24 Oct 2014 Corporate tax Tax Projects Construction Advisory & Disputes Infrastructure UK Europe In a report on… – Continue reading

OECD gives cautious welcome to Knowledge Box tax scheme

THE OECD has signalled support for the Government’s plan to introduce a so-called “Knowledge Development Box”, but warned that the devil would be in the detail. Pascal Saint-Amans, the director of the Centre for Tax Policy and Administration at the Paris-based Organisation for Economic Cooperation and Development (OECD), told the… – Continue reading

Tax survey stresses excessive scrutiny, significance of BEPS

A new survey by E&Y released at its 33rd Annual International Tax Conference, titled “Connecting the dots” uncovered the issues of navigating multiple challenges, led by increased scrutiny and the effects of the Organisation for Economic Co-operation and Development’s (OECD) base erosion and profit shifting (BEPS) project. “Tax directors need… – Continue reading

Interest deductions: the new war on base erosion

ITR Correspondent • • • The G20 and OECD’s Base Erosion and Profit Shifting (BEPS) project has rarely been out of the headlines during 2014. At the heart of the BEPS project is the assumption international tax rules make it possible for profits to be taxed in countries that are… – Continue reading

Improving Transparency and Combating Tax Avoidance to Top Agenda of Ninth Forum on Tax Administration, on 23-24 October 2014 in Dublin, Ireland

21/10/14-Tax administrations will play a central role as governments move to implement the measures they have agreed to counter offshore evasion and combat tax avoidance by multinational enterprises. Global initiatives like the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project and the move toward automatic exchange of financial account account… – Continue reading

Cash-strapped countries eye trillions held offshore

Foreign structures are tempting targets for governments, says Vanessa Houlder. When governments around the world embarked on a drive to plug tax loopholes in 2012, the urgency of the move was underpinned by rising tensions over austerity and inequality. Widespread public outrage over alleged tax-dodging by wealthy individuals and multinationals… – Continue reading

ATO Commissioner Urges Int’l Collaboration On BEPS

Unprecedented international collaboration is needed to overcome a single-, isolated-country view to tackling base erosion and profit shifting (BEPS) issues, Andrew Mills, Second Commissioner of Australian Taxation Office (ATO) for Law Design and Practice, has said. In a speech delivered at the Second Annual Tax Forum organized by the Tax… – Continue reading

BEPS already an issue, says CICA

The Organization for Economic Cooperation and Development’s (OECD) plan for base erosion and profit shifting (BEPS) is already affecting corporations, according to speakers participating in a Captive Insurance Companies Association (CICA) transfer pricing webinar. Polling results during the webinar revealed attendees’ opinions were in line with tax industry surveys indicating… – Continue reading

Luxembourg: Update Of The OECD Model Tax Convention

On July 15th 2014, the OECD published its 2014 update of the Model Tax Convention (“2014 OECD Update”). This update is the outcome of the work accomplished between 2010 and the end of 2013. It does not however take into account the OECD conclusions of the “Action Plan on Base… – Continue reading

Davis Tax Committee mulls ways to ‘detect and deter’ corporate tax avoidance

The revenue implications for South Africa of ‘base erosion and profit shifting’ by corporate taxpayers are firmly in the crosshairs of the Davis Tax Committee (DTC) and Judge Dennis Davis hinted on Monday that recommendations were being considered to “detect and deter” tax-avoiding financial flows. Speaking at a G20 study… – Continue reading

The changing business model

There has been a lot of press coverage recently around the pricing and tax arrangements of multinationals, in particular Apple, Starbucks and Amazon. In this respect, the EU is undertaking in-depth investigates into these companies to establish whether the companies’ tax arrangements have breached EU State Aid rules. These cases… – Continue reading

Irish Budget 2015 – Rate, Regime, Reputation

Our Reaction The Irish Minister for Finance delivered his Budget 2015 (the “Budget”) speech this week. There was considerable domestic and international anticipation in advance of the Budget against a backdrop of significant recovery in the Irish economy and also international focus (including, in particular, under the OECD BEPS project)… – Continue reading

Ministers reassuring key foreign firms on closure of ‘Double Irish’

Budget measures including new foreign direct investment incentives discussed State agencies and Government Ministers and officials have launched a co-ordinated campaign of letters and phone calls to senior executives of foreign multinationals, to reassure them that Ireland remains a top destination for investment following the budget, Minister for Enterprise Richard… – Continue reading

Strong rules on transfer pricing on agenda in many countries

AMONG several proposals for tax reform, the director-general of the Revenue Department has said the agency would propose an amendment to the Revenue Code concerning transfer pricing, aiming to provide greater clarity on the determination of fair transfer prices. The director-general has indicated that in past years many multinational companies,… – Continue reading

Bringing back black money: Swiss promise India details in time-bound manner

erne/New Delhi: In a major breakthrough in India’s fight against black money allegedly stashed abroad, Switzerland today said it will examine Indian requests for banking information on a priority basis and provide requested details in a time-bound manner. The Swiss authorities would also “assist in obtaining confirmation on genuineness of… – Continue reading