Category: Tax Planning

OECD Releases First CbC Reporting Peer Reviews

The OECD has released the first peer reviews of the country-by-country (CbC) reporting initiative, reporting that practically all countries that serve as headquarters to large multinationals have introduced new transfer pricing documentation requirements to improve transparency. Country-by-country reporting will see tax administrations worldwide collect and share detailed information on all...

OECD backs BEPS plan in face of critics

The OECD has endorsed New Zealand’s crackdown on multi-national tax evasion, despite significant criticism from local businesses that it departs from OECD standards, Thomas Coughlan reports. David Bradbury, head of the OECD’s tax policy and statistics division, told Newsroom that the OECD was “very pleased with the strong support that...

Tax outflows, debt cripples Malawi’s growth

Malawi is struggling to address loss of revenues due to smuggling of minerals, unregulated artisanal and small-scale mining activities, under declaration of taxable income and transfer mispricing by mining companies. Reserve Bank of Malawi statistics show that Malawi lost $980 million (MWK78 billion) between 2010 and 2017 due to foreign...

HMRC To Add To Arsenal Against Diverted Profits

HM Revenue and Customs (HMRC) has launched a consultation inviting input on proposals to tackle arrangements entered into by individuals, partnerships, or companies that aim to move UK profits outside the scope of UK taxation, typically through the use of offshore trusts and companies. The new legislation, to be drafted...

UK property tax changes affect GCC nationals

  PROPERTY in the UK, particularly London, has always been popular with GCC investors for many years. It has remained a safe haven and an attractive destination for investors and their families from the GCC region perhaps more than any other major city. Depending on the level of investment, well...

Argentina Extends CbC BEPS Reporting Deadline

Argentina’s Federal Administration of Public Income has extended the filing deadline for country-by-country (CbC) notifications. Taxpayers who are part of multinational enterprises now have until May 2, 2018, to file CbC notifications where the ultimate parent company of the multinational group has a December 2017 fiscal year end. The CbC...

India Defers Surrogate Entity CbC Reporting Deadline

The Indian Central Board of Direct Taxes has issued a statement to defer the filing obligation on surrogate parent entities with regards to country-by-country reporting. Section 286 was inserted into the Income Tax Act 1981 through the 2016 Finance Act to introduce a requirement to furnish a country-by-country report. The...

Foreign groups in India have to provide country-by-country report, clarifies govt

All international groups operating in the country will have to provide a country-by-country (CbC) report as per the revised Income tax Act, the government clarified in a finance ministry release issued today. The CbC report is to be furnished by the ultimate parent entity of an international group in the...

Malta Backs EU Crackdown On Aggressive Tax Planning

Malta has reiterated its commitment to fighting aggressive tax planning, joining other EU member states who have unanimously agreed to amend the EU’s tax information sharing law, the Directive on Administrative Cooperation. The amendments to the Directive, which were agreed last week by EU finance ministers, will require intermediaries, such...

Mauritius Finalizes CbC Reporting Regulations

Mauritius last month released the Income Tax (Country-by-Country Reporting) Regulations 2018, setting out the jurisdiction’s rules concerning the filing by multinational groups of transfer pricing documentation. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under BEPS Action 13. Under the framework,...

LUX RULES “MAY FACILITATE AGGRESSIVE TAX PLANNING”

The European Commission has criticised Luxembourg and six other EU member states for overly favourable tax treatment of multinational corporations. “The @EU_Commission is today stressing the issue of aggressive tax planning in seven EU countries: #Belgium, #Cyprus, #Hungary, #Ireland, #Luxembourg, #Malta and The #Netherlands. #FairTaxation,” Pierre Moscovici, the European finance...

Hong Kong Launches CbC Reporting Portal

Hong Kong’s Inland Revenue Department on March 5 launched its new Country-by-Country Reporting Portal. Groups can now register to file CbC reports for accounting periods beginning between January 1, 2016, and December 31, 2017, using the online portal. The CbC report is one element of a new three-tiered standardized approach...

Australia Announces Upcoming Guidance On Int’l Tax Matters

The Australian Tax Office has updated and added to its list of the guidance on international tax matters it intends to release this year. This month, the ATO intends to release a guide on corporate residency – central management and control in Australia [reference code 3838], to provide the ATO’s...

Dutch Cabinet Approves Anti-Evasion Measures

The Government of the Netherlands has announced a comprehensive package of tax anti-avoidance proposals designed to bring the jurisdiction’s rules into line with new European Union anti-avoidance laws and fulfill its obligations under the international BEPS agenda. The plans were detailed in a parliamentary paper sent by State Secretary for...

Singapore Updates Guidance On Transfer Pricing Regime

The Inland Revenue Authority of Singapore (IRAS) on February 23, 2018, released the fifth edition of its Transfer Pricing Guidelines for income tax. During a public consultation held in June 2017, stakeholders asked the Ministry of Finance to provide more clarity and guidance on transfer pricing documentation (TPD) requirements, specifically...

FDI enterprises pay lowest taxes despite high profits

HÀ NỘI– Foreign direct investment (FDI) enterprises, which have enjoyed multiple tax incentives, pay the lowest State taxes despite reporting high profits, statistics show. FDI enterprises have achieved the highest profit growth among the economic sectors, generating VNĐ327.4 trillion (US$14.4 billion) in pre-tax profits in 2016, an increase of 17.3...

IRB Casts Dragnet For Tax Dodgers This Year

SUBANG: The Inland Revenue Board (IRB) will this year put in place strong measures to deter tax avoidance and evasion by focusing on individuals and firms engaging in such misconduct. Chief Executive Officer (CEO) Datuk Dr Sabin Samitah said the offences included those who engaged in aggressive tax planning, by...

Ukraine updates transfer pricing rules for 2018: key takeaways

Ukraine’s Law No. 2245-VIII “On Introduction of Changes to the Tax Code of Ukraine and Some Legislative Acts of Ukraine on Ensuring the Balance of Budget Revenues in 2018,” which came into effect on January 1, 2018, includes important changes to transfer pricing (TP) regulations. These changes are outlined below....

US Inc. urges Jaitley to reduce tax uncertainty for MNCs

Washington–Ahead of Finance Minister Arun Jaitley’s last full Union Budget, the US-India Business Council (USIBC) has urged him to further reduce tax uncertainty for multinational companies and foreign investors, even as Indian industry has voiced its own areas of concern. In a memorandum submitted to Jaitley, the USIBC has said...

Hong Kong BEPS Bill: New Transfer Pricing Regime to Regulate Documentation

On December 29, 2017, the Inland Revenue (Amendment) (No. 6) Bill 2017 (BEPS bill) was gazetted in Hong Kong. The BEPS bill introduces a transfer pricing regulatory regime and mandatory transfer pricing documentation requirement in Hong Kong as well as a variety of other anti-BEPS changes. The BEPS bill marks...

Transfer Pricing Dispute Resolutions in India: New Relaxations

The Income Tax Department recently released a clarification stating that it would accept requests for mutual agreement procedures (MAPs) and bilateral advance pricing agreements (BAPAs) in transfer pricing disputes with all countries regardless of the existence of specific provisions in the Double Taxation Avoidance Agreements (DTAAs). A 2012 survey by...

Bulgarian Presidency Outlines EU Tax Plans

The “fair and efficient” taxation of corporate profits and the fight against tax avoidance and evasion through enhanced administrative cooperation are among the priorities of the new Bulgarian presidency of the European Union, which commenced on January 1, 2018. The recently released program of the Bulgarian presidency states that it...

India Signs Three Further APAs During December

India entered into three more advance pricing agreements in December, with two unilateral agreements and a bilateral APA concluded with authorities in the United Kingdom. With the signing of these agreements, the total number of APAs entered into by the Central Board of Direct Taxes totals 189, comprising 173 unilateral...

Transfer Pricing and BEPS to Increase Tax Revenues in Georgia

The FINANCIAL — Transfer Pricing Rules were implemented by the Government of Georgia in 2011, based on OECD guidelines. Since the number of international companies in Georgia is increasing steadily, Transfer Pricing Rules have become a point of obvious interest. However, multinational companies operating in Georgia are not sufficiently well-informed...

Serbia to Abolish Full Blown Withholding Tax on Non-Resident Service-Providers and Simplify Conditions for Tax Deductibility of NPL Write-Offs for Serbian Banks

The Serbian Ministry of Finance has published draft amendments to the Corporate Income Tax Act (CITA), which are expected to be formally approved by the Government within days. If approved by the Parliament, as expected, CITA amendments will take effect from 1 January 2018. The most important novelties concerns recognition...

Bermuda To Exchange MNE Tax Info With The UK

Bermuda and the UK recently signed an agreement providing for the automatic exchange of country-by-country reports. Bermuda is the first UK Overseas Territory to sign a CbC Competent Authority Agreement with the UK, which enables the automatic reporting of corporate income on a country-by-country basis for UK-related transfer pricing enforcement...

India to accept mutual agreement process in transfer pricing cases

NEW DELHI The Indian Income Tax Department will accept applications for Mutual Agreement Procedure (MAP) in transfer pricing disputes, as well as for bilateral Advance Pricing Agreements (APAs), even for entities resident in countries with which India has double taxation avoidance agreements (DTAA), minus the provision to claim corresponding tax...