On October 26, Hong Kong’s Government launched a public consultation on the implementation of base erosion and profit shifting (BEPS) measures proposed by the OECD. “Hong Kong is supportive of international efforts to promote tax transparency and combat tax evasion,” said Secretary for Financial Services and the Treasury K C… – Continue reading
The International Monetary Fund (IMF), the Organisation for Economic Co-operation and Development (OECD), the UN Department of Economic and Social Affairs (DESA), and the World Bank Group introduced a joint initiative, the Platform for Collaboration on Tax, to UN Member States. Marijn Verhoeven, World Bank Group, expressed excitement that the… – Continue reading
With the exception of British Antarctica, the U.K.’s overseas territories and offshore dependencies are all surrounded by sun-winking ocean water. But that’s not their only common feature—they are all under increasing political pressure to become more transparent with their financial information. In a parliamentary report on tackling overseas corruption, the… – Continue reading
New Chief Minister Howard Quayle MHK has restated the island’s commitment to tax transparency at an Organisation for Economic Co-operation and Development event in Paris. Mr Quayle was in Paris for the Manx government’s signing of a new OECD agreement on automatic exchange of country by country reporting by large… – Continue reading
The OECD has set the minimum standards it requires from countries submitting Mutual Agreement Procedure (MAP) profiles, with only 41 countries currently having a completed profile, which will be used as a tool for resolving cross-border tax disputes The MAP falls under Action 14 on the Base Erosion and Profit… – Continue reading
The Governments of Japan and Austria have agreed in principle to amend their double taxation avoidance agreement to further promote trade and investment between the two countries. The new agreement would enable arbitration under the mutual agreement procedure to ensure settlement of double tax disputes. The new agreement will also… – Continue reading
On October 14, 2016, Andorra became the 86th territory to join the OECD’s new inclusive framework on base erosion and profit shifting (BEPS). As a member of the framework, Andorra will commit to implementing the minimum standards put forward by the OECD on BEPS. These are on: harmful tax practices,… – Continue reading
The OECD tax team is calling on tax professionals and multinationals to participate in an online survey on tax certainty, responding to widespread concerns about the increasing complexity of tax rules and lack of stability for companies and multinationals over tax regulations. This follows the detailed work on the OECD’s… – Continue reading
One of the most common ways multinationals take advantage of current laws to reduce their tax bill is through what’s known as transfer pricing. Former Treasurer Wayne Swan last week accused mining giant BHP of “aggressive transfer pricing,” denying the Australian government A$5.7 billion in tax revenue. For most companies,… – Continue reading
Applicable to transfer pricing for MNCs whose consolidated annual revenue is over Rs 5,000 crore The finance ministry will issue rules and guidance to address some concerns and ambiguity over mandatory reporting norms with respect to transfer pricing for multinational companies whose consolidated annual revenue is over Rs 5,000 crore…. – Continue reading
European Union plans to regulate tax advisers in an effort to clamp down on aggressive tax planning and tax avoidance could prove excessive, ineffective and trigger unfair competition, accountants and lawyers warn. The caution comes after EU finance ministers moved Oct. 11 to authorize the European Commission to draw up… – Continue reading
Tough rules to regulate tax advisers, banks and lawyers who help companies avoid tax are set to be advanced by European Union finance ministers. The Council of Economic and Financial Affairs Oct. 11 also will likely move toward a system of automatic exchange of beneficial ownership registers to better target… – Continue reading
Finance Minister Sri Mulyani Indrawati has said the ongoing tax amnesty program was in line with global efforts to prevent and combat tax base erosion and profit shifting (BEPS) and would not accommodate any money laundering efforts. Tax amnesty programs have brought benefits to the many countries that have implemented… – Continue reading
The Inland Revenue Authority of Singapore (IRAS) has published detailed guidance on the implementation of a new country-by-country (CbC) reporting requirement in the territory. The guidance, released on October 10, sets out which entities are obliged to report and how to complete and submit a CbC report to IRAS. For… – Continue reading
During a recent speech, the Secretary for Financial Services and the Treasury, K C Chan, reiterated Hong Kong’s commitment to meeting the international standards on tax transparency, and to implementing the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profits shifting (BEPS) package. In his speech on October… – Continue reading
EY announced today the results of a new tax survey at its 35th Annual International Tax Conference, “Unlocking the future.” The survey revealed that, more than ever, companies are experiencing an increasing number of audits and more aggressive enforcement from tax authorities around the world. According to the survey, nearly… – Continue reading
Chances of tax evaders coming under the scanner is rising due to the implementation of the GST, greater use of technology and exchange of information between countries New Delhi: The noose is tightening around tax evaders. Be it the implementation of the goods and services tax (GST) or the greater… – Continue reading
Ireland, accused of being a tax haven for multinationals such as Apple to pay nearly zero tax on the bulk of its profits earned outside the United States, finds itself with a new adversary in the global fight against unfair tax practices — Brazil. As of October 1, Brazil will… – Continue reading
Around 35 per cent of businesses in India have changed their tax approach following the OECD Base Erosion and Profit Shifting (BEPS) tax plan, higher than the global average, says a report. The Grant Thorntons recently conducted global survey of 2,600 businesses in 36 countries, found little impact of the… – Continue reading
A multi-billion euro back tax bill handed to Apple by the European Commission should not be seen as a precedent for future tax cases as it was based on state aid rather than tax law, the OECD official spearheading global tax reform said on Monday. European Union antitrust regulators last… – Continue reading
The Director of the OECD’s tax policy and administration unit has said there is no pressure on Ireland to change its 12.5% tax rate. “There is no question about the 12.5% rate, even the French have understood that Ireland will not change the rate,” Pascal Saint-Amans said. He said the… – Continue reading
The threshold could be R5,400 crore of annual consolidated group revenue for the purpose of country-by-country reporting Not more than 120 India-headquartered firms — along with their global associates — are likely to be impacted by the base erosion and profit shifting (BEPS) protocol once it is implemented, as the… – Continue reading
Nearly a year after release of the OECD Base Erosion and Profit Shifting (BEPS) anti tax avoidance action plan, which introduces changes to the treatment of interest deductibility and profit shifting, the majority of businesses have not changed their approach to tax compliance. The major economies in the G7 (83%),… – Continue reading
China’s State Administration of Taxation (SAT) issued the Announcement on the Administration of Related-party Transactions and Contemporaneous Documentation (SAT Announcement [2016] No. 42), which introduces a three-tiered documentation framework that will replace its current transfer pricing documentation rules. The June 29 announcement followed the publication of the opinion-seeking draft by… – Continue reading
OECD Secretary General Angel Gurría has stressed the need for policy makers to provide a certain tax environment for businesses, to maintain trade and investment. Discussing the tax challenges facing EU countries at the informal meeting of EU finance ministers, held in Bratislava, Slovakia, on September 10, 2016, Gurría said:… – Continue reading
Apple Inc. may face double taxation on some of its profits if the European Commission’s Aug. 30 ruling inspires France to slap its own tax adjustment on the company, practitioners said. Apple could even face “triple taxation” if it repatriates profits from the European Union to the U.S., Laurent Leclercq,… – Continue reading
The Special Administrative Region yesterday signed a Tax Information Exchange Agreement (TIEA) with Ireland, according to an announcement by the Financial Services Bureau. The agreement was inked by the Secretary for Economy and Finance, Lionel Leong Vai Tac and Ireland’s Ambassador to China, Paul Kavanagh. According to the Secretary, the… – Continue reading
The G20 summit in China has stressed the need for international tax cooperation to achieve ‘a globally fair and modern international tax system’, after US President Obama warned of the risks if countries ‘race to the bottom’ in tax policies At a press conference at the conclusion of the summit,… – Continue reading
The international tax landscape has been changing rapidly and the Organisation for Economic Co-operation and Development (OECD) has agreed on a base erosion and profit shifting (Beps) action plan that could affect businesses operating in the UAE. The plan addresses the issue of artificial shifting of profits and its proposals… – Continue reading
The International Chamber of Commerce (ICC) has expressed concern about the possible broader implications of the European Commission’s (EC’s) ruling against Apple. In a statement published on September 1, the ICC warned that unprecedented rulings of this nature fall outside the scope of the recommendations of the OECD’s base erosion… – Continue reading
A coalition of Silicon Valley tech companies has urged the Dutch Government against making changes to the most “attractive” features of its corporate tax regime, warning that it risks damaging its traditionally strong tax competitiveness by doing so. The Silicon Valley Tax Directors Group (SVTDG), which includes more than 80… – Continue reading
Recent developments in the global business environment which are characterized by intense competition and rapid growth of multinational enterprises have led to new business models and structuring of business operations in order to meet the increasing demands of expansion on a global scale. Agency arrangements, as a way for enterprises… – Continue reading
Disclosures under the MAP are aimed at improving dispute resolution mechanism and are part of global initiative on base erosion and profit shifting. India will soon disclose the number of disputes being negotiated under the mutual agreement procedures (MAP) of tax treaties as well as details of the time being… – Continue reading
Under EU rules it is illegal for countries to give financial help to some companies and not others in a way that distorts fair competition, writes Liza Lovdahl Gormsen. State aid rules were originally designed to protect the internal EU market and avoid retaliation among member states. The US Treasury,… – Continue reading
The US has warned the EU that it risks damaging international agreements on tax reform if it continues to act as a “supra-national tax authority”. The US Treasury Department “shares the European Commission’s concern with tax avoidance by multinational firms. The international community, including the EU and its member states,… – Continue reading
On August 22, 2016, Liechtenstein filed its instrument of ratification of the Multilateral Competent Authority Agreement on country-by-country (CbC) reporting. With the move, Liechtenstein will be able to share the information contained in the CbC reports with tax treaty partners that have implemented the necessary reporting standards. Liechtenstein was among… – Continue reading
The OECD is consulting on the mechanics of dealing with branch mismatch structures under Base Erosion & Profit Shifting (BEPS) Action 2, designed to neutralise the effects of hybrid mismatch arrangements as part of the wider anti-avoidance action plan The BEPs project has already released a report on Action 2,… – Continue reading
THE OECD/G-20 Base Erosion and Profit Shifting (BEPS) Project is designed to provide solutions for governments to close the gaps in existing international rules that allow corporate profits to “disappear” or be artificially shifted to low or no tax environments, where companies have little or no economic activity. In February… – Continue reading
An IRS official said the agency is continuing its work on a mechanism to allow voluntary filings of country-by-country reports for companies required to comply with both the U.S. rules and those in a foreign country with an earlier effective date. “Actually being able to accept CBC reports for the… – Continue reading
Companies doing business in Luxembourg will be required to file global tax information now that the nation has released draft legislation to implement new international tax reporting rules. The rules—known as country-by-country reporting—would require companies to submit a global blueprint outlining the location of their operations, taxes paid, income earned,… – Continue reading
In May 2016, the Cambodian and Singaporean government authorities signed a new agreement to avoid double taxation with respect to taxes on income and on capital. What are the objectives and benefits of a double taxation avoidance (DTA) agreement? The “big-picture” objectives of the DTA between Singapore and Cambodia are… – Continue reading
Budget 2016 introduced a new tax called Equalisation Levy (“EL”), aimed at taxing online transactions. EL was originally mooted by the OECD in Base Erosion and Profit Shifting (BEPS) Project Final Report on Action 1 – Addressing the Tax Challenges of the Digital Economy (the “Report”). We will examine Equalisation… – Continue reading
Despite Western opposition, the 134-member Group of 77 is continuing to pursue a longstanding proposal for an inter-governmental UN-affiliated tax body aimed at combating corporate tax dodging and curbing illicit financial flows, including money laundering and off-shore banking. The proposal has already been shot down twice by Western nations, first,… – Continue reading
The Section of Taxation of the American Bar Association (ABA) has written to the US Internal Revenue Service (IRS) saying that there is a pressing need for guidance from tax authorities due to the rapid growth of the cloud industry. The ABA noted that, although the Organisation for Economic Co-operation… – Continue reading
Transfer pricing documentation rules have come to the fore with the United Kingdom’s Brexit. The European Union and the Organization for Economic Cooperation and Development appear to apply similar transfer pricing documentation rules to multinational companies, but differences nevertheless abound. Some multinational enterprises may view these differences as nuances, but… – Continue reading
Possible EU sanctions against New Zealand could make travel harder and have a massive effect on the economy. New Zealand is under investigation by the EU as it prepares a blacklist of global tax havens, Newshub revealed on Monday night. The grouping of 28 European nations has compiled a list… – Continue reading
At the recent G20 meeting in China, finance ministers stressed their support for greater tax transparency, calling for a report from the OECD on the implementation of automatic exchange of information before the end of the year, and stating that by July 2017 it wants a list of non-compliant jurisdictions… – Continue reading
International tax experts are to convene in Canada on August 29-31, 2016, to discuss global transfer pricing developments and other issues affecting large corporations as a result of the OECD’s base erosion and profit shifting (BEPS) project. Bloomberg BNA and Baker and McKenzie will host two events: The 3rd Annual… – Continue reading
Tax executives at U.S.-based multinational companies are having a hard time adjusting to the new rules demanded by the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting plan, also known as OECD BEPS, according to a new survey. While OECD BEPS is not a requirement in the… – Continue reading
The German Federal Cabinet has adopted a bill to implement key aspects of the OECD’s base erosion and profit shifting (BEPS) recommendations and the European Union’s administrative cooperation directive. The Act Concerning the Implementation of Changes to the EU Administrative Cooperation Directive and of Additional Measures against Base Erosion and… – Continue reading
