Senator Orrin Hatch (R – Utah) has said that lowering the United States’ corporate tax rate to one of the lowest in the world should be a top priority in current tax reform efforts. The Chairman of the Senate Committee on Finance said that the US corporate rate, one of… – Continue reading
Montenegro has shown its commitment to improving compliance with international tax standards. The FATCA Agreement is yet another example of a set of steps taken towards broadening the cooperation between the US and Montenegro and following the international standards of cross-border tax assistance. The US Ambassador, Margaret Ann Uyehara and… – Continue reading
The Australian Tax Office is preparing to take several companies to court over abuse of thin capitalisation rules and will start a wave of audits of large multinationals with complex cross-border loans, as it continues to take a hardline approach in the wake of its win against Chevron. The ATO… – Continue reading
Cameroon has officially become the 70th country to adhere to the convention of the Organisation for Economic Co-operation and Development (OECD), on mutual administrative assistance in tax matters. The act of accession to this convention has just been signed between OECD and the Cameroonian Minister of Finance, Alamine Ousmane Mey…. – Continue reading
Irish Finance Minister Paschal Donohoe has explained the country’s approach to tax evasion during a hearing of the European Parliament’s PANA Committee, and said Ireland is “a strong supporter of international tax reform efforts.” Donohoe was one of several European finance ministers who appeared before the committee on July 11…. – Continue reading
German Finance Minister Wolfgang Schaeuble defended his opposition to pending European Union legislation that would force large multinational companies to publicly disclose, on a country-by-country basis, their taxes paid and profits. Schauble, who testified before the EU Parliament’s Panama Papers investigative committee July 11, said public reporting of companies’ tax… – Continue reading
Most Asian countries are not collecting enough tax to meet their goals and they need to boost revenue by taking steps at home and by working with other countries, the deputy managing director of the International Monetary Fund said. In much of Asia, the tax-to-GDP ratio “consistently” falls below the… – Continue reading
Australian small businesses are frustrated over the introduction of the “Netflix tax”, with claims the government is failing to properly crack down on multinational tax avoidance. As Australian consumers prepare to fork out up to 20 per cent more for digital services, business owners are calling foul, declaring the tax… – Continue reading
The Revenue received 24% more requests for assistance from overseas governments with probes into taxpayers from overseas jurisdictions last year A freedom of information (FOI) request from law firm Pinsent Masons found that a total of 2,015 requests had been made to HMRC last year, up from 1,619 in 2015…. – Continue reading
As of 1st July 2017, the tax treatment of intra-group financing arrangements has been amended in Cyprus. Intra-group financing transactions refers to finance activities between related parties (as defined in Section 33 of the Income Tax Law), including permanent establishments in Cyprus. Based on the Interpretative Circular issued by the… – Continue reading
Among the products purchased by the Ministry are: Onesource Benchmark and Onesource TP Loan Module. Thomson Reuters and Ministry of Taxes of the Republic of Azerbaijan have signed an agreement under which the Ministry will use Thomson Reuters tax solutions aimed at implementing tax control in the sphere of transfer… – Continue reading
France wants Brussels to take a tougher stance on American multinationals working inside the European Union (EU) and force them to pay an appropriate amount of tax. “I can tell you that the times we live in are not for the weak,” French Finance Minister, Bruno Le Maire said in… – Continue reading
Slovakia is the first V4 country to sign the agreement on country-by-country reporting. Slovakia’s Financial Administration has obtained easier access to the information of US multinational companies. The representatives of Slovakia and the US signed a bilateral agreement on country-by-country (CbC) reporting on June 21, the TASR newswire reported. The… – Continue reading
Obama-administration regulation drew criticism as overbroad Trump ordered review of tax rules that may pose undue burdens A federal rule aimed at limiting corporate “earnings stripping’’ for tax-avoidance purposes may pose an undue burden on taxpayers and may be changed or rescinded, according to a U.S. Internal Revenue Service notice…. – Continue reading
Mauritius has signed the Multilateral Convention to Implement Tax Treaty Related Measures to prevent Base Erosion and Profit Shifting (MLI). Once ratified, the MLI will affect as many as 23 tax treaties entered into by this island nation, which has been an important jurisdiction for routing investments into India. Interestingly,… – Continue reading
Companies will have to disclose “uncertain” tax positions, including amounts disputed by the Australian Tax Office, under new accounting rules designed to increase information available to investors. Australia will adopt international accounting guidance with effect from 2019 that RSM Australia national technical director Ralph Martin said would result in some… – Continue reading
Who is required to file, how it should be filed and what is necessary to disclose. Several South African-based multinational companies have less than six months to prepare their country-by-country reports for exchange with other tax jurisdictions. Many have realised the magnitude of the information expected and have been setting… – Continue reading
The European Parliament on Tuesday passed a directive requiring big multinationals to report tax and financial data separately in all countries where they operate, a measure aimed at tackling tax avoidance and profit shifting to countries with lower taxes. The new rules are part of a wider overhaul of tax… – Continue reading
EU Tax Commissioner Pierre Moscovici has described the proposed common consolidated corporation tax base as a “decisive tool against corporate tax avoidance.” Moscovici made the comment during a speech on tax fairness. He said the CCCTB will provide companies with a single rulebook for calculating their taxable profit throughout the… – Continue reading
Introduction Finance Act 2016 replaced the test for corporate residency of foreign companies from “control and management being situated wholly in India” to “place of effective management (POEM) in India”. POEM has been defined to mean a place where key management and commercial decisions that are necessary for conduct of… – Continue reading
The Internal Revenue Service has created a new section on its IRS.gov website dedicated to information on the Country-by-Country Reporting rules of the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting project, which aims to discourage tax avoidance by multinational companies. The new Country-by-Country Reporting web pages… – Continue reading
On June 28, 2017, the Swiss Federal Council adopted the dispatch on a revised double taxation agreement with Latvia and submitted it to Parliament for approval. A protocol to revise the agreement was signed by the two countries in November 2016. The revised agreement contains an anti-abuse clause in line… – Continue reading
Sri Lankan companies that violate transfer pricing rules can be fined up to two percent of the total value of transactions between related parties in case of non-disclosure of any required information under the new tax law. The new law also provides for the Commissioner-General of Inland Revenue to impose… – Continue reading
The OECD has released for stakeholders’ comments two new discussion drafts as part of its base erosion and profit shifting work. The first draft builds on the OECD’s final report on BEPS Action 7 (on preventing the artificial avoidance of permanent establishment status). The final Report on Action 7 of… – Continue reading
Ghana signed another Double Tax Agreement (DTA) with the Czech Republic on 11 April, 2017. Ghana already has DTAs in force with Denmark, the United Kingdom, Belgium, Italy, South Africa, Switzerland, Netherlands, France and Germany. DTAs with Mauritius, Singapore and the Czech Republic are in the process of being ratified… – Continue reading
The Australian Taxation Office has reversed its stance on the tax treatment of trustee dividend-equivalent payments to participants in employee share schemes. The ATO’s June 8 draft guidance, Draft determination TD 2017/D2, deals with circumstances in which an employer establishes a trust to provide shares to employees under an employee… – Continue reading
Global leader in cross-border information exchange for Tax Authorities has been selected by the Government of Bermuda, Ministry of Finance, Treaty Unit to meet Common Reporting Standards. Today, Vizor Ltd. announced the Government of Bermuda, Ministry of Finance, Treaty Unit has selected the Vizor for FATCA & AEOI Solution for… – Continue reading
Tax returns and annual financial disclosures contain different information Candidates and members of Congress are required by law to file personal financial disclosures that are designed to shed a light on their potential conflicts of interest. These documents show a lawmakers’ assets and liabilities, reported in broad ranges. Tax returns,… – Continue reading
European Union-based multinational companies that exceed consolidated revenue of 750 million euros ($840 million) for two consecutive years would have to report publicly on taxes paid, profits earned, and persons employed on a country-by-country basis, under a proposal from Malta. Malta holds the EU presidency, a position it will turn… – Continue reading
A. Introduction In February 2017 Cyprus Tax Department has announced that the current practice regarding profit margins between related Company loans will be abolished by the 30th June 2017. The announcement indicates that the minimum acceptable margins will apply up to 30th June 2017, and as from 1st July 2017… – Continue reading
Tax Administration Jamaica (TAJ) reported on Tuesday that local financial institutions required to report under the Foreign Account Tax Compliance Act (FATCA) are now 100 per cent compliant. FATCA is United States legislation designed to target US taxpayers holding accounts and assets outside that country and are non-compliant with US… – Continue reading
A new report shows the offshore jurisdiction is home to assets of $1.5tn, double an estimate by the International Monetary Fund in 2010. Assets held offshore in the British Virgin Islands (BVI) are worth $1.5 trillion (£1.19 trillion), double the International Monetary Fund’s 2010 estimate. That’s according to a new… – Continue reading
Indian immigrants in Saudi Arabia are set to be hit by the Kingdom’s newly introduced ‘family tax’ that will come into effect starting from July 1. The tax requires employed persons to pay a fee of 100 riyals (Rs 1,700 approx) per dependent each month. So, an Indian expat living… – Continue reading
The Senate Committee on Finance has asked for public input on US tax reform options. The Chairman of the Senate’s tax-writing committee, Orrin Hatch (R – UT), wrote an open letter asking stakeholders to provide ideas, proposals, and feedback on how to improve the US tax system. “It is essential… – Continue reading
The Canada Revenue Agency (CRA) has said that audits it undertook between April 2015 and March 2017 of real estate transactions resulted in more than CAD329.4m (USD249.2m) in assessed income that had not been reported. The CRA said that, during this period, it completed over 21,000 audit files related to… – Continue reading
New Delhi, June 19 (IANS) The Central Board of Direct Taxes (CBDT) on Monday said it has operationalised the provisions of secondary adjustment in transfer pricing. The Finance Act, 2017 with effect from April 1, 2018 provided for secondary adjustment by attributing income to the excess money lying in the… – Continue reading
India has, for long, been always regarded as the one of the most aggressive transfer pricing jurisdictions. To mend this image and reduce litigation, the government introduced various measures like Advance Pricing Agreements (APA), the safe harbour regime, risk-based selection of transfer pricing audit cases etc. While most of these… – Continue reading
President Donald Trump and Republican leaders in Congress will soon confront a complex challenge for tax reform: how to limit U.S. corporate tax avoidance schemes that take advantage of low tax rates in foreign countries. Congressional and administration staff have begun to examine options to address profit-shifting schemes that include… – Continue reading
The Government Emergency Ordinance no. 42/2017 amending Law no. 207/2015 regarding the Fiscal Procedure Code (“GEO 42/2017“), entered into force on 13 June 2017, transposes within the Romanian legislation the EU Directive 2016/881 which provides the mandatory automatic exchange of information from reports that multinational enterprise groups (“MNE Groups“) must… – Continue reading
Nigeria has ratified multilateral conventions on tax related treaties to end profit shifting and tax evasion by multinational companies. The ratification of the treaties Wednesday followed the approval of a memo submitted by the Minister of Finance, Kemi Adeosun, who said this was part of government’s plan to widen its… – Continue reading
The new Common Reporting Standard (CRS) regime will apply to most Australian managed investment schemes from 1 July 2017. Additional procedures for collecting information from new investors will need to be introduced from this date and additional work will be required in respect of existing investors. Overview of CRS Many… – Continue reading
The Organisation for Economic Co-operation and Development (OECD) announced on Tuesday that Botswana has joined the Inclusive Framework on base erosion profit shifting (BEPS) becoming the framework’s 99th member.The Inclusive Framework on BEPS is a group of countries that have pledged to implement measures designed by OECD and G20 countries… – Continue reading
HA NOI — Viet Nam’s long-standing efforts to tackle the practice of transfer pricing as a tax avoidance ploy have gained sharper legal teeth with a new decree. Transfer pricing is the pricing of goods, services and intangibles between related parties, like a parent company and its affiliates. Apart from… – Continue reading
In Federal Budget 2017, the Government is clamping down on tax avoidance by foreign investors in real estate, by tightening the foreign resident capital gains tax withholding regime. The new laws apply to both Australian resident and foreign resident vendors: Australian resident vendors of real property of $750,000 or more… – Continue reading
SOUTH Australia is set to become the most competitive tax jurisdiction for commercial investment in Australia according to Collier’s International’s latest Radar research. The boast is prompted by the introduction, on July 1, of the state government’s second stamp duty reform which will come into effect as part of comprehensive… – Continue reading
The OECD is seeking taxpayers’ input on the mutual agreement procedure (MAP) frameworks in place in the third batch of countries that will now be peer reviewed under Action 14 of the OECD’s base erosion and profit shifting Action Plan: the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, and… – Continue reading
Senior officials and ministers from 67 countries and jurisdictions have signed an agreement that is designed to make it harder for multi-national companies to avoid tax through the strategic use of cross-border shifting of profits. The US was not among either the 67 countries to have signed the so-called Multilateral… – Continue reading
Regulator Sebi is mulling tightening its investigation and enforcement mechanism to check misuse of stock market platform for generating “bogus” long-term capital gains to launder black money. The markets watchdog has also come across cases wherein fraudulent tax benefits have been claimed through trades in some blue-chip stocks, as against… – Continue reading
Cairn Energy has petitioned an international arbitration tribunal against billionaire Anil Agarwal-led Vedanta Ltd withholding its dividend for last three years New Delhi: UK’s Cairn Energy plc has petitioned an international arbitration tribunal against billionaire Anil Agarwal-led Vedanta Ltd withholding its dividend for last three years despite tax authorities saying… – Continue reading
Chevron has decided to take its tax battles to the High Court of Australia after it was reported that the supermajor is in the crosshairs of the Australian Tax Office (ATO) for a disputed AU$1 billion outstanding tax bill. This comes after the Federal Court ruled in favor of the… – Continue reading
