Category: Tax Planning

Nigeria seeks IMF’s support on tax collection

The Federal Government is seeking assistance from the International Monetary Fund (IMF) on modalities for improving tax collection, especially from the International Oil Companies (IOCs), Finance Minister Zainab Ahmed, has said. She told reporters on the sidelines of the ongoing 2018 International Monetary Fund (IMF)/World Bank Group Meetings, in Bali,...

Tax Avoidance Taskforce helps net $5.6 billion in first two years

The more detailed scrutiny of the tax affairs of multinationals, large corporations and wealthy individuals, made possible by the formation of the Tax Avoidance Taskforce, has collected $5.6 billion in extra tax in just two years. Deputy Commissioner Mark Konza said “the $679.9 million the Government funded the ATO for...

NBI probe in Turku targets real estate firm, nabs third suspect

A large-scale police operation into money laundering appears to have targeted the Airiston Helmi real estate firm, led by a Russian man with Maltese citizenship. An exceptionally large police operation took place in southwest Finland this weekend, in what the National Bureau of Investigation (NBI) said was an extensive search...

Sweden takes measures to tackle tax evasion, financial crimes

STOCKHOLM, Sept. 4 (Xinhua) — The Swedish government has proposed three new measurements to tackle aggressive tax planning, evasion and financial crimes, the Government Offices of Sweden said Tuesday. The proposals include increased international automatic information exchange, new possibilities for the Swedish Tax Agency to prevent financial crimes and tighter...

FIRS Publishes Nigeria’s Revised Transfer Pricing Regulations

Federal Inland Revenue Service has published Nigeria’s revised Transfer Pricing Regulations (NTPR). The NTPR is effective for basis periods commencing after 12 March 2018 and incorporates BEPS outcomes and suggestions from The African Tax Administration Forum. The NTPR includes significant penalties for non-compliance (a) failure to file TP declaration =...

Crypto Islands as Double Offshore

There is a small island in the Caribbean … You immediately imagine relaxation, a beach, palm trees. However today in these small areas a really big crypto history is being created. The crypto business is increasingly mastering the jurisdiction of “dwarf” states, such as Cyprus, Malta, Gibraltar, The Republic of...

Facebook, Coke could face tax hit after ruling against Medtronic

Last week, Medtronic Plc suffered a legal setback in its bid to avoid a $1.4 billion U.S. tax bill — a ruling that may have costly implications for other multinationals battling the Internal Revenue Service over the use of overseas payments to lower their taxes. Companies including Facebook Inc. and...

Intra-group Service Fee Treatment in China

Most multinational corporations (MNCs) charge their subsidiaries for services like human resources (HR) or information technology support. The subsidiary’s payment for these services is classed as intra-group service fees when they are made within same enterprise group. Because some businesses use this method to avoid tax and shift profits, tax...

PM asks authorities to probe tax evasion by FDI firms

Media reports have suggested the Government to build a more effective mechanism to tackle the problem that prolonged loss-making FDI enterprises have still enlarged investment and production. — Photo cafebiz.vn Viet Nam News HA NOI – Prime Minister Nguyen Xuan Phuc has assigned the Ministry of Finance (MOF) and General...

Profit shifting a regional issue: Palaso

Profit shifting by large companies is a regional issue that can be addressed through improved information sharing between tax authorities of economies, says Internal Revenue Commission commissioner-general Betty Palaso. She said this at the opening of the Advancing Base Erosion and Profit Sharing (BEPS) and Automatic Exchange of Information (AEOI)...

Inland Revenue (Amendment) (No. 6) Ordinance 2018 gazetted

Hong Kong (HKSAR) – The Inland Revenue (Amendment) (No. 6) Ordinance 2018, which primarily implements the minimum standards of the Base Erosion and Profit Shifting (BEPS) package promulgated by the Organisation for Economic Co-operation and Development (OECD) and codifies the transfer pricing principles into the Inland Revenue Ordinance (Cap. 112)...

The use of UK holding companies in international group structures – tax considerations

From a commercial viewpoint it is important that the Holdco is located in a reputable jurisdiction when seeking to access international equity and debt capital markets. The choice of Holdco location will also be relevant in circumstances where private equity investment is envisaged or where a trade sale is planned....

More Information… More Intense Transfer Pricing Disputes?

The Central Board of Direct Taxes has recently issued guidance on the appropriate use of the ‘Country-by-Country Report’. The CbC filing was introduced as a result of the OECD/G20 Base Erosion and Profit Shifting project. India also introduced the requirement to file CbC reporting recently with the completion of the...

Transfer pricing disputes: Interest payout relief coming for MNCs

CBDT issues draft notification on interest computation NEW DELHI, JUNE 20 The Central Board of Direct Taxes (CBDT) proposes to provide a relief to MNCs on the interest payable by them on the untaxed profits stashed abroad, requiring to be repatriated back to India under the transfer pricing regime. It...

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...