Category: Base Erosion & Profit Shifting

Base Erosion & Profit Shifting / Corporate Tax / Country-by-Country (CbyC) Reporting / Internal Revenue Service (IRS) / Multinational Enterprises ("MNEs") / OECD / Regulatory / Transfer pricing / USA

GAO-17-103, International Taxation: Information on the Potential Impact on IRS and U.S. Multinationals of Revised International Guidance on Transfer Pricing, January 27, 2017

Posted On: January 27, 2017

What GAO Found In 2015, the Organization for Economic Co-Operation and Development (OECD) issued revised guidelines, including 15 actions to help reduce base erosion and profit shifting (BEPS) of multinational enterprises (MNEs). One action focuses on transfer pricing guidance with the intent of aligning MNE profits with the location of… – Continue reading

Base Erosion & Profit Shifting / IMF / Multinational Corporations / Multinationals / OECD / Transfer pricing / UN

OECD consults on developing countries transfer pricing toolkit

Posted On: January 26, 2017

The OECD is seeking feedback on a draft toolkit designed to assist developing countries in work on transfer pricing, which specifically addresses the ways developing countries can overcome a lack of data on ‘comparables’, or the market prices for goods and services transferred between members of multinational corporations The toolkit… – Continue reading

Base Erosion & Profit Shifting / Brazil / Chile / Colombia / Country-by-Country (CbyC) Reporting / Legislation / Mexico / Multilateral Competent Authority Agreement / OECD / Peru / Revenue / Transfer pricing / USA

New transfer pricing requirements in Latin America under BEPS

Posted On: January 25, 2017

Several countries in Latin America have established new transfer pricing documentation obligations associated with the OECD’s Base Erosion and Profit Shifting (BEPS) initiative. In this new year, Mexico, Colombia and Peru have included in their local legislation new documentation requirements that follow a three-tiered approach: country-by-country (CbC) report, master file,… – Continue reading

Apple / Australia / Base Erosion & Profit Shifting / Bermuda / Google / Ireland / Multinationals / OECD / Oxfam / Profit Shifting / Tax Avoidance / Tax Haven / Tax treaties

Bermuda – the world’s former ‘No.1 tax haven’ – joins fight against multinationals

Posted On: January 24, 2017

Bermuda – the world’s former “top tax haven” – has joined the Organisation for Economic Cooperation and Development’s fight against multinational profit shifting. Bermuda disputes it is a tax haven despite companies such as Apple and Google in the past being accused of using the British overseas territory to minimise… – Continue reading

Base Erosion & Profit Shifting / Debt / Hedge Fund / Investments / Jurisdiction / OECD / Private Equity Funds / Property / Real Estate / Tax Authority / Tax Laws / Tax treaties

OECD’s MLI: will tax treaty benefits apply to private equity investors?

Posted On: January 24, 2017

The OECD recently released a public discussion draft entitled the “BEPS Action 6 Discussion Draft on non-CIV examples” to clarify when investors like private equity funds, real estate funds and hedge funds should be entitled to tax treaty benefits. The release of the 2017 Discussion Draft is timely, given that… – Continue reading

Base Erosion & Profit Shifting / Earnings stripping / G20 / Germany / Income Tax / Income Tax Act / Jurisdiction / OECD / Offshore / Related party Transactions / Royalties / Tax Authority / Tax Deductibility / Tax Evasion / Tax Planning

BEPS – Germany on the way to limit the tax deductibility of royalties

Posted On: January 23, 2017

A new legislative approach of the German tax authorities leaked last December 19 will have a significant impact on the tax deductibility of royalties owed to related persons being subject to a preferential back end tax regime for IP not being in compliance with the Organisation for Economic Co-operation and… – Continue reading

Base Erosion & Profit Shifting / Cyprus / Framework / Gaar / India / Investments / Jurisdiction / Mauritius / OECD / PWC / Regulatory / Singapore / Tax Avoidance / Tax Haven / Tax Laws / Tax treaties

Multilateral Instrument: The new dilemma of foreign investors

Posted On: January 22, 2017

MUMBAI: The Multilateral Instrument (MLI), a new global tax avoidance agreement, that is in the process of being signed by 100 countries, is now causing a lot of anxiety among foreign portfolio investors (FPIs). MLI is an agreement put out by OECD, the intergovernmental economic organisation, to stop Base Erosion… – Continue reading

Base Erosion & Profit Shifting / Capital gains / Cyprus / Europe / France / Gaar / Income Tax Act / India / Jurisdiction / Mauritius / Netherlands / OECD / Singapore / Spain / Tax Avoidance / Tax treaties

International tax-avoidance rules may override GAAR, other tax treaties

Posted On: January 19, 2017

There is a possibility that the General Anti-Avoidance Rules (GAAR, on taxes) and the tax treaties signed by the government with those of Mauritius, Singapore and Cyprus, and even other nations such as Netherlands, could be overtaken by another event. These could, say experts, be partially or fully overridden by… – Continue reading

Base Erosion & Profit Shifting / Country-by-Country (CbyC) Reporting / EU / European Commission / Germany / Multilateral Competent Authority Agreement / Mutual Agreement Procedure / Tax Authority / Transfer pricing

German Multinationals Fear Disclosure of Global Tax Reports

Posted On: January 19, 2017

Multinational companies headquartered in Germany worry that when they report their global tax and profits for 2016, some countries will leak their country-by-country reports to the press. German parents of multinational groups with annual consolidated group revenue of at least 750 million euros ($797 million) are required to file, with… – Continue reading

Base Erosion & Profit Shifting / Business / Income Tax / Individuals / Inequality / Malaysia / Multinational Corporations / Revenue / Tax Authority / Tax Avoidance / Tax Evasion / Tax Planning

Tackling aggressive tax planning

Posted On: January 18, 2017

THERE was a time when a tax professional would confidently tell you that tax avoidance would not get you in trouble. You might be bending the rules a little to minimise your tax liability, but as long as you followed the letter of the law, you would be fine. On… – Continue reading

Australia / Base Erosion & Profit Shifting / Britain / Corporate Tax / G20 / Google / Income Tax / Multinationals / OECD / Offshore / Oxfam / Profit Shifting / Revenue / Tax Avoidance / United Kingdom

Plans for Australia to adopt a ‘Google tax’ welcomed by advocacy group

Posted On: January 16, 2017

Coalition’s proposed diverted profits tax could capture billions in revenue from multinationals using profit-shifting practices, says Tax Justice Network One of the biggest critics of multinational tax avoidance has welcomed the Coalition’s proposed “Google tax”, saying a similar tax in the UK looks likely to increase corporate tax payments by… – Continue reading

Amsterdam / Australia / Base Erosion & Profit Shifting / Business / Canada / Corporate Tax / Facebook / France / Google / Income Tax / Jurisdiction / LinkedIn / Luxembourg / Multinational Corporations / OECD / Saudi Arabia / Tax Planning / Twitter / United Kingdom / USA

Snapchat opts for London over Dublin for international HQ

Posted On: January 10, 2017

Move could be a worrying indicator of investment trends post-Brexit, post-Beps Snap, the company behind Snapchat, has opted to open its new new international headquarters in London, rather than Dublin, Amsterdam or Luxembourg, bucking a trend which for decades has seen US multinationals book their international sales in one of… – Continue reading

Automatic Exchange of Information / Base Erosion & Profit Shifting / Business / Country-by-Country (CbyC) Reporting / Cyprus / Framework / Jurisdiction / Multilateral Competent Authority Agreement / Multinationals / Residence / Tax Laws

Cyprus: Country-By-Country Reporting Under Base Erosion And Profit Shifting Action 13

Posted On: January 9, 2017

Cyprus signed the Organisation for Economic Co-operation and Development’s Multilateral Competent Authority Agreement for the Automatic Exchange of Country-by Country Reports between its member states on 1 November 2016 after approval by the Council of Ministers at its meeting held on 28 September 2016. Following publication in the government gazette… – Continue reading

Activity / Apple / Base Erosion & Profit Shifting / Business / Coca-Cola / Controlled Foreign Corporation / Corporate Tax / Double Taxation / Employment / Europe / Income Tax / Intellectual Property / Inversion / Investments / Jurisdiction / Multinational Corporations / OECD / Panama / Revenue / Tax Authority / Tax Collection / Tax competition / Tax Evasion / Tax Planning

Worldwide: The OECD’s Conquest Of Domestic Tax Codes: Understanding The Costs And Consequences Of The BEPS Project

Posted On: January 9, 2017

Authored by IFC Media Recent global events from the release of the Panama Papers to a series of high-profile inversions have given international tax regulators both rhetorical ammunition and public support to execute a global crackdown on multinational tax planning. The goal is to increase total taxes paid by global… – Continue reading

Base Erosion & Profit Shifting / Bermuda / Cote d'Ivoire / Framework / Jurisdiction / Kazakhstan / OECD

Three More Nations Commit To BEPS Minimum Standards

Posted On: January 9, 2017

A further three countries have committed to participate in international base erosion and profit shifting discussions and implement minimum standards, under the OECD’s new “inclusive framework” for countries. The OECD confirmed on January 6 that the three territories are: Bermuda, Côte d’Ivoire, and Kazakhstan. This brings the total number of… – Continue reading

Base Erosion & Profit Shifting / Hong Kong / Interest / OECD / Tax Laws / Transfer pricing

Hong Kong Needs Measured BEPS Response: Report

Posted On: January 6, 2017

Hong Kong’s Financial Services Development Council (FSDC) has issued a paper setting out key recommendations for the Government to consider in the area of international tax law. The paper, which was issued on December 29, 2016, recommends that the Government should issue clearer guidance on appropriate transfer pricing methodologies for… – Continue reading

Base Erosion & Profit Shifting / Country-by-Country (CbyC) Reporting / Double Tax Treaty / Europe / G20 / Jurisdiction / Legislation / Multilateral Competent Authority Agreement / Multinational Enterprises ("MNEs") / OECD / Permanent establishment / Residence / Switzerland / Tax Authority / Tax Information Exchange Agreements / Transfer pricing

Switzerland: Federal Council Adopts Dispatch On Exchange Of Country-By-Country Reports

Posted On: January 5, 2017

On 23 November 2016, the Swiss Federal Council adopted the dispatch on the Multilateral Agreement on the exchange of Country-by-Country Reports (CbCRs) and draft federal implementing legislation. The proposal is aimed at implementing the minimum standard of the G20 countries and the OECD to combat base erosion and profit shifting… – Continue reading

Base Erosion & Profit Shifting / Business / Europe / Germany / Legislation / Offshore / Statute of Limitation / Tax Avoidance / Tax Evasion / Tax Haven / Tax treaties / Treaty Abuse

German Government Targets Offshore Tax Avoidance

Posted On: January 2, 2017

The German Government has adopted draft anti-avoidance legislation intended to make it more difficult for domestic taxpayers to avoid tax through the use of “mailbox companies in tax havens.” The draft bill, approved by the Cabinet on December 21, contains more stringent reporting obligations for German taxpayers with foreign financial… – Continue reading

Automatic Exchange of Information / Base Erosion & Profit Shifting / Capital gains / Capital Gains Tax / Cyprus / Double Tax Avoidance Treaty / Double Taxation / India / Interest / Investments / KPMG / Mauritius / Mutual Agreement Procedure / Residency / Revenue / Shares / Singapore / Switzerland / Tax Avoidance / Tax Evasion / Tax Laws / Transfer pricing

Singapore Goes The Mauritius Route, Loses Right To Tax Equity Capital Gains Arising In India

Posted On: January 1, 2017

Starting April 1, 2017, India will have the right to tax capital gains arising on Indian equity shares sold by a Singapore resident. The governments of India and Singapore have amended the double taxation avoidance treaty between the two countries, in line with the changes India recently made to a… – Continue reading

Africa / Anti money laundering / Base Erosion & Profit Shifting / Beneficial Ownership / Business / Common Reporting Standard / FATCA / Framework / Germany / Individuals / Investments / Jurisdiction / Mauritius / Multilateral Convention on Mutual Administrative Assistance in Tax Matters / OECD / Oxfam / Regulatory / Tax Evasion / Tax Haven / USA

Mauritius: Joint Statement By The FSC & The FSPA

Posted On: December 19, 2016

The Mauritius IFC: Driving Growth in Africa As a jurisdiction of substance, the Mauritius International Financial Centre (Mauritius IFC) has been instrumental in driving quality investments in Africa, leading to sustained growth and prosperity across the continent. It is therefore with deep regret that we take note of the misperceptions… – Continue reading

Amazon / Apple / Base Erosion & Profit Shifting / Budget / Digital Services / Facebook / Google / IBM / India / LinkedIn / Microsoft / Multinationals / Netflix / OECD / Revenue / Tax Evasion / Tax Laws / Yahoo

Apple, Netflix, MS and IBM may have to pay `google tax’

Posted On: December 17, 2016

The `Google tax’ could soon ensnare the likes of IBM, Microsoft, Amazon Web Services, Apple and Netflix, which provide online services in India. Cloud computing companies and content providers with customers in the country may be needed to pay equalisation levy on their revenue from the next financial year as… – Continue reading

Asia / Base Erosion & Profit Shifting / Business / Corporate Tax / Country-by-Country (CbyC) Reporting / Directors / Europe / Multinationals / OECD / Tax competition / Tax Evasion / Tax Planning / USA

Multinational CFOs increasingly view tax as reputational risk

Posted On: December 16, 2016

Tax directors and CFOs at multinational companies are facing increasing numbers of tax audits, and are becoming concerned about the impact of public perception of their tax planning on their company’s reputation, according to research by Taxand. Its fifth annual global survey of CFOs, tax and finance directors across Europe,… – Continue reading

Activity / Banking Secrecy / Base Erosion & Profit Shifting / Bermuda / Business / Corporate Tax / Dividends / Interest / Investments / Jurisdiction / Oxfam / Singapore / Switzerland / Tax Evasion / Tax Haven / Withholding Tax

MOF rejects claim of Singapore as tax haven

Posted On: December 14, 2016

A recent report has revived claims Singapore is a tax haven but the Singapore Government and experts here reject the label emphatically. They say the report contains inaccurate assertions and fails to recognise recent steps here to crack down on tax evasion. The Republic ranked fifth on a list of… – Continue reading

Automatic Exchange of Information / Base Erosion & Profit Shifting / G20 / Monaco / Multilateral Convention on Mutual Administrative Assistance in Tax Matters / OECD / Tax Evasion

Monaco ratifies international tax convention

Posted On: December 14, 2016

Monaco has ratified the Convention on Mutual Administrative Assistance in Tax Matters. The ratification underlines Monaco’s commitment to fighting tax evasion and avoidance. It also means the principality has taken another important step in implementing the Standard for Automatic Exchange of Financial Account Information in Tax Matters, developed by the… – Continue reading

Australia / Base Erosion & Profit Shifting / Corporate Tax / Multinationals / New Zealand / Tax Arrangement / Tax Avoidance / Tax Dodging / Tax Planning / Transfer pricing / United Kingdom

Government planning action to target multinationals over tax

Posted On: December 14, 2016

The Government is planning unilateral action to crack down on tax dodging by multinational companies, including changing the law, amid growing concern about fairness. Revenue Minister Michael Woodhouse said proposals outlined in a cabinet discussion document tabled last month would see Inland Revenue properly armed to tackle the problem and… – Continue reading

Apple / Base Erosion & Profit Shifting / Bermuda / Cayman Islands / Corporate Tax / Cyprus / EU / European Commission / Intellectual Property / Ireland / Jurisdiction / Legislation / Luxembourg / Multinationals / Netherlands / OECD / Oxfam / Property Tax / State Aid / Tax Arrangement / Tax Avoidance / Tax Break / Tax Haven / Tax Laws

Ireland Rejects Oxfam’s Tax Haven Claims

Posted On: December 13, 2016

Ireland’s Ministry of Finance, the EU and several other governments have emphatically rejected claims by Oxfam International that the countries are tax havens, with Ireland insisting its corporate tax laws are “fully compliant” with international best practices when it comes to transparency and information exchange. The Irish government said the… – Continue reading

Base Erosion & Profit Shifting / Beneficial Ownership / Bermuda / Business / China / Corporate Tax / France / Germany / Japan / Jurisdiction / Multinationals / OECD / Offshore / Oxfam / Panama / Regulatory / Tax Avoidance / Tax Haven / Tax Information Exchange Agreements / Tax Reform / Tax Transparency

Richards accuses Oxfam of ‘serial errors’

Posted On: December 13, 2016

Finance minister Bob Richards has expressed dismay at Oxfam’s claim that Bermuda is the world’s worst corporate tax haven. And the Progressive Labour Party joined him to condemn the report as “extremely disappointing”. Mr Richards pointed to “serial errors” in the global charity’s report on offshore centres, which found that… – Continue reading

Asia / Base Erosion & Profit Shifting / Business / Controlled Foreign Corporation / Corporate Tax / Dividends / EU / Europe / Goods and Services Tax / Hong Kong / Hungary / Income Tax / Intellectual Property / Inversion / Investments / Ireland / Jurisdiction / Luxembourg / Multinationals / Netherlands / OECD / Permanent establishment / Rand Paul / Revenue / Singapore / State Aid / Statutory / Switzerland / Tax competition / Tax Planning / Tax Reform / Transfer pricing / United Kingdom / USA / VAT / Washington / Withholding Tax

Rate Competition Is New International Tax Planning Reality

Posted On: December 13, 2016

Lower corporate tax rates around the world are expected to play an important part in multinational companies’ tax planning in 2017, with a rate as low as 15 percent on the table in the U.S. and countries such as the U.K. planning to maintain or lower their current rates. A… – Continue reading

Base Erosion & Profit Shifting / Corporate Tax / Double Taxation / EU / Gaming / Luxembourg / Malta / Multinational Corporations / OECD / Tax Avoidance

International taxation changes could ‘pose a major challenge’ to Malta’s iGaming sector

Posted On: December 13, 2016

Changes in the way international taxation is collected, thanks to recommendations made by the Organisation for Economic Cooperation and Development (OECD) could “pose a major challenge to the sustainability and profitability” of many iGaming operations in Malta. This information came to light through a report issued by Country Profiler on… – Continue reading

Bank of China / Base Erosion & Profit Shifting / China / Commercial Bank of china / Double Taxation Agreement / Income Tax / Industrial and Commercial Bank of China / Interest / Loans / Multilateral Convention on Mutual Administrative Assistance in Tax Matters / OECD / Pakistan / Tax Exempt

Pak-China avoidance of double taxation treaty inked

Posted On: December 10, 2016

ISLAMABAD – Pakistan and China signed third protocol to the avoidance of double taxation agreement that would allow a Chinese bank and a state-owned investment fund to avail income tax exemption on interest income from loans for energy projects under China-Pakistan Economic Corridor (CPEC). Federal Board of Revenue (FBR) Chairman… – Continue reading

Base Erosion & Profit Shifting / Business / Double Taxation / G20 / International Chamber of Commerce / Jurisdiction / Multinationals / OECD / Paris / Permanent establishment / Siemens / Tax Dispute / Tax treaties / Transfer pricing / Treaty Abuse

ICC welcomes adoption of OECD Multilateral Convention

Posted On: December 6, 2016

The International Chamber of Commerce (ICC) welcomes the Organisation for Economic Co-operation and Development’s (OECD)’s release last week of a multilateral convention which allows for swift implementation of a series of tax treaty measures encompassed in the OECD/G20 Base Erosion and Profit Shifting (BEPS) project. The release follows the conclusion… – Continue reading

Activity / Andorra / Base Erosion & Profit Shifting / Blacklist update / Business / Cayman Islands / Common Reporting Standard / Country-by-Country (CbyC) Reporting / EU / Europe / Jurisdiction / Liechtenstein / Monaco / Multilateral Convention on Mutual Administrative Assistance in Tax Matters / Multinationals / OECD / Offshore / San Marino / Switzerland

Cayman commits to BEPS rules to counter EU blacklist

Posted On: December 6, 2016

Also commits to country-by-country reporting Cayman has committed in principle to a project reforming the application of tax rules in cross-border business to combat the erosion of tax bases and the artificial shifting of profits to low or no-tax jurisdictions. Developed by the Organization for Economic Cooperation and Development, base… – Continue reading

Activity / Andorra / Automatic Exchange of Information / Base Erosion & Profit Shifting / Bulgaria / Business / Cayman Islands / Common Reporting Standard / Corporate Tax / Estonia / European Parliament / FATCA / Income Tax / Individuals / Ireland / Jurisdiction / Liechtenstein / Malta / Monaco / OECD / Offshore / Panama / San Marino / Slovakia / Switzerland / Tax Evasion / Tax Haven / United Kingdom

EU Mulls ‘Substance Test’ to Determine Zero-Rate Tax Havens

Posted On: December 1, 2016

European Union member countries are considering a “substance test” to determine whether a country or jurisdiction with a zero corporate tax rate qualifies as a tax haven that doesn’t reflect “real economic activity.” After a host of EU member countries rejected in early November the use of a zero corporate… – Continue reading

Australia / Australian Taxation Office / Base Erosion & Profit Shifting / Business / Corporate Tax / Corporates / European Commission / Google / Interest / Ireland / Legislation / Microsoft / Multinational Anti-Avoidance Law / Multinationals / OECD / Profit Shifting / Singapore / Tax Arrangement / Tax Avoidance / United Kingdom

Australia’s Google Tax may be the second in the world but it’s too early to tell if it’s the ‘toughest’

Posted On: December 1, 2016

When introducing the draft legislation for the Diverted Profits or so-called “Google Tax”, Federal Treasurer Scott Morrison claimed it would: …reinforce Australia’s position as having amongst the toughest laws in the world to combat corporate tax avoidance. Australia is the second country to introduce this type of tax, after the… – Continue reading

Base Erosion & Profit Shifting / Jurisdiction / Multinationals / OECD / Tax Avoidance / Tax treaties / Treaty Abuse

Multilateral Treaty Not Simple, But Clear: OECD’s Saint-Amans

Posted On: November 30, 2016

The OECD’s ground-breaking multilateral tax treaty, which will potentially amend thousands of bilateral tax treaties, will add “another layer” to treaty administration—but actual changes to bilateral agreements will be clear to both tax administrations and multinational companies, the organization’s tax chief said. Taxpayers and tax administrations “will know what the… – Continue reading

Base Erosion & Profit Shifting / Country-by-Country (CbyC) Reporting / Double Taxation / Framework / Interest / Jurisdiction / OECD / Permanent establishment / Tax Planning / Tax treaties / Transfer pricing / Treaty Abuse / Ukraine

Ukraine officially joins BEPS project

Posted On: November 24, 2016

On November 22, 2016, the Minister of Finance of Ukraine handed an official letter on Ukraine’s accession to the BEPS (Base Erosion and Profit Shifting) plan to the Secretary-General of OECD. Being the final stage in the process of joining the project, Ukraine is to become a member of the… – Continue reading

Amazon / Apple / Base Erosion & Profit Shifting / Fees / France / Google / Intellectual Property / Legislation / Multinationals / New Zealand / OECD / Paris / Permanent establishment / Tax Deductions / Transfer pricing / USA

French Panel Adopts ‘Google Tax’ on Diverted Profits

Posted On: November 18, 2016

Big U.S. internet companies in France could get hit by a new BEPS-inspired penalty on “diverted profits” under a so-called Google tax measure that France’s National Assembly is set to consider next week. The amendment, proposed by Socialist Deputy Yann Galut and adopted by the Assembly’s finance committee, targets foreign… – Continue reading

Banking Secrecy / Base Erosion & Profit Shifting / Beneficial Ownership / Cayman Islands / EU / Germany / Individuals / Jurisdiction / OECD / Panama / Tax Authority / Tax Avoidance / Tax Evasion / Tax Planning / USA

Germany Prepares Crackdown on Letterboxes

Posted On: November 16, 2016

Nov. 15 — The German Cabinet is preparing to address a bill Dec. 21 to combat tax evasion by cracking down on letterbox companies and banking secrecy as a response to the Panama Papers and other scandals involving sophisticated forms of tax planning. The bill, prepared by the Federal Ministry… – Continue reading

Base Erosion & Profit Shifting / Bulgaria / Corporate Tax / Double Taxation / EU / European Commission / France / Germany / Ireland / Legislation / Malta / Multinationals / OECD / State Aid / Tax Break / Tax competition / Tax Credit / Transfer pricing

Common Base Could End EU Patent Box, Transfer Pricing Disputes

Posted On: November 16, 2016

Adoption of legislation for a common consolidated corporate tax base by 27 EU member states would resolve current patent box conflicts and end transfer pricing disputes that cost multinational companies hundreds of millions of dollars in double taxation, according to EU and industry officials. Speaking at a Nov. 15 conference… – Continue reading

Base Erosion & Profit Shifting / Beneficial Ownership / Blacklist update / Business / Cayman Islands / Common Reporting Standard / Controlled Foreign Companies / Corporate Tax / EU / Europe / Income Tax / Italy / Jurisdiction / OECD / Offshore / Shell / Tax Evasion / Tax Haven / Tax Information Exchange Agreements / Tax Transparency

Cayman may find itself on EU’s ‘non-cooperative jurisdictions’ list

Posted On: November 15, 2016

Cayman could find itself on a new EU list of “non-cooperative jurisdictions” in tax matters after the European Council of finance ministers published the criteria for including third countries in the blacklist last week. The provisions emphasize that a jurisdiction “should not facilitate offshore structures or arrangements aimed at attracting… – Continue reading

Base Erosion & Profit Shifting / Business / China / Double Taxation / EU / European Commission / European Parliament / India / Individuals / Jurisdiction / Legislation / Multinationals / OECD / Panama / Slovakia / Tax Avoidance / Tax Haven

EU Parliament May Lose Right to Veto Public Tax Reporting

Posted On: November 14, 2016

The European Parliament risks losing the right to veto plans to make multinational companies publish tax and profit details for the countries in which they operate, according to the European Union’s legal advisers. The Council of Ministers’ legal service insisted in its opinion, seen by Bloomberg BNA, that the European… – Continue reading

Base Erosion & Profit Shifting / Europe / European Commission / Individuals / OECD / Pierre Moscovici / Revenue / Tax Evasion / Tax Planning

EU To Crack Down On Promotion Of Aggressive Tax Planning

Posted On: November 11, 2016

The European Commission has launched a public consultation on how best to deter promoters of aggressive tax planning schemes. The Commission said it is particularly interested in gathering views on how a mandatory disclosure scheme for tax advisers could be put in place. If implemented, this would require intermediaries to… – Continue reading

Base Erosion & Profit Shifting / Business / Interest / Jurisdiction / Legislation / Multinationals / New Zealand / OECD / Permanent establishment / Profit Shifting / Tax treaties / Transfer pricing / Treaty Abuse

New Zealand Planning More BEPS Measures

Posted On: November 10, 2016

New Zealand’s tax agency has set out the international tax initiatives it intends to pursue, in particular in response to the OECD’s base erosion and profit shifting plan. It said it will undertake further work on a package of BEPS initiatives, which will include hybrid mismatch rules to prevent companies… – Continue reading

Australia / Base Erosion & Profit Shifting / Business / Corporate Tax / France / Interest / Multinationals / New Zealand / OECD / Revenue / Tax Authority / Tax Avoidance / Tax Deductions / Turkey / United Kingdom

IRD delayed multinational tax crackdown

Posted On: November 9, 2016

New Zealand has delayed cracking down on multinational tax avoidance due to private sector concerns over timing and concerns about “scaring away” foreign investment, the Inland Revenue Department says. Wide-ranging reforms to corporate tax rules proposed by the Organisation for Economic Cooperation and Development (OECD), known as the base erosion… – Continue reading

Andorra / Arbitration / Base Erosion & Profit Shifting / Canada / China / Deloitte / Double Taxation / Ernst & Young / Framework / London / Multinationals / Mutual Agreement Procedure / OECD / Panama / Permanent establishment / Singapore / Tax Avoidance / Tax Dispute / Tax treaties / Transfer pricing / United Kingdom / USA / Washington

Nearly 100 Countries Poised to Adopt Multilateral Treaty

Posted On: November 8, 2016

Ninety-eight countries are poised to formally adopt the OECD’s innovative multilateral tax treaty, which will place recommendations from the BEPS project into more than 3,000 bilateral accords, when the ad-hoc group meets later this month. The “Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting”… – Continue reading

Austria / Base Erosion & Profit Shifting / Business / Country-by-Country (CbyC) Reporting / Ernst & Young / Europe / Germany / Mexico / Multinational Corporations / Netherlands / New York / Privacy / Tax Authority / Tax Avoidance / Transfer pricing / Washington

Country-by-Country Confusion: Narrow BEPS Queries Abound

Posted On: November 4, 2016

Global governments battling tax avoidance increasingly are pushing multinational corporations for a bigger picture of how and where they pay taxes, leading to increasingly narrow questions from company tax officers. “We have a number of entities that are disregarded for U.S. tax purposes. When I fill out the country-by-country form,… – Continue reading

Australia / Australian Taxation Office / Base Erosion & Profit Shifting / Goods and Services Tax / OECD / Offshore

Australian Goods And Services Tax Guidance For Offshore Suppliers

Posted On: November 2, 2016

The Australian Tax Office (ATO) has updated its guidance for those non-resident businesses that make supplies of goods, services, or digital products to consumers or GST-registered businesses in Australia, with a couple of changes due to occur next year and a change last month. Since October 1, 2016, certain transactions… – Continue reading

Base Erosion & Profit Shifting / Country-by-Country (CbyC) Reporting / Egypt / G20 / Jurisdiction / Legislation / Multinationals / OECD / Pakistan / Qatar / Saudi Arabia / Transfer pricing / UAE

MENA Transfer Pricing in a Post BEPS World

Posted On: November 2, 2016

Historically, the Middle East and North Africa (MENA) region has been perceived as a region where taxation and transfer pricing initiatives are not high up on government agendas. Although this has been the case for a significant period of time, recent changes in the region such as decreases in global… – Continue reading

Base Erosion & Profit Shifting / Corporate Tax / EU / European Commission / Interest / Legislation / Multinationals / OECD / Romania / Tax Avoidance

Romania plans to join project for fighting big companies’ tax avoidance

Posted On: November 2, 2016

Romania plans to join the Base erosion and profit shifting (BEPS) program as an associate member. The program equips governments with domestic and international instruments to address tax avoidance. The program’s objective is to have profits taxed where economic activities generating the profits are performed. The Finance Ministry has published… – Continue reading

Base Erosion & Profit Shifting / Belgium / Canada / Double Taxation / Jurisdiction / Multinationals / Mutual Agreement Procedure / Netherlands / OECD / Offshore / Switzerland / Tax Planning / Tax treaties / United Kingdom / USA

OECD Reviewing U.S. Handling of Double-Tax Cases

Posted On: November 1, 2016

The OECD has started to review how effectively the U.S. and five other countries handle cases in which multinational companies assert double taxation under the mutual agreement procedure of bilateral tax treaties. As part of the review, the Organization for Economic Cooperation and Development is inviting multinationals to answer a… – Continue reading

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