Both internal and external factors threaten politics, economics Hong Kong’s run of good luck is running out. One obvious sign is the increasing interference of Beijing in its domestic affairs, most recently using tame Chief Executive C.Y. Leung and a clique of yes-men to interfere in a senior academic appointment… – Continue reading
At the beginning of the week, the Organization for Economic Cooperation and Development—an international organization founded to advise industrial nations on economic policy—proposed a plan to address what has become an important international issue: tax avoidance. The OECD, in response to a request to look at the tax rules international… – Continue reading
NEW DELHI: Within days of getting a favourable verdict in the Rs 8,500 crore transfer pricing case from the Bombay High Court, Vodafone Group CEO Vittorio Colao will call on Finance Minister Arun Jaitley this week. Colao will visit India on October 14 and is scheduled to meet Jaitley the… – Continue reading
The OECD’s base erosion and profit shifting (BEPS) final reports that focus on transfer pricing are comprised of a number of updates to different parts of existing OECD transfer pricing guidance. In particular, BEPS Actions 8-10 are designed to provide that transfer pricing outcomes are aligned with value creation, and… – Continue reading
The Government has expressed a commitment to improving levels of UK corporate transparency but a recent Private Eye article [1], documenting the extent of ownership of British Land through offshore entities, shows just how far there is to go. By far the most common reason for owning UK property through… – Continue reading
The hedge fund trade to gain exposure and then encourage a U.S. corporation to enter into an acquisition transaction with a foreign corporation where it incorporates internationally to lower its tax burden, known as a corporate inversion, might have slowed of late, but the issue is now being addressed at… – Continue reading
Emmanuel Mayah, Jeff Mbanga, Francis Kokutse and Nick Mathiason contributed to this joint investigation by the M&G Centre for Investigative Journalism (amaBhungane) and Finance Uncovered, a global reporting project involving journalists in 54 countries. Shortly after Cyril Ramaphosa left MTN to become South Africa’s deputy president last year, he lashed… – Continue reading
The Swiss Government has tasked the Finance Ministry with responding to the OECD’s recommendations on base erosion and profit shifting. Welcoming the OECD’s proposals, the Council said: “In general, the project outcomes will allow for [the] better coordination of international tax law rules and make it possible to close the… – Continue reading
The fallout for Australian firms from the BEPS project “won’t be radical in Australia, as we have already moved pre-emptively to strengthen our laws,” Assistant Treasurer Kelly O’Dwyer has said. Commenting on the release of the OECD’s final BEPS reports, O’Dwyer said: “The Coalition Government’s measures line up with the… – Continue reading
This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 (Projet de loi de finance pour 2016) issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December (“Draft Finance Bill for… – Continue reading
EVENT OVERVIEW Globally, countries are campaigning for watertight tax regimes and gradually but definitely towards commercially driven business practices, and BEPS seems to be the way to it. Around 44 countries, including India, have come together to create a code to enable looking at transactions with a borderless lens for… – Continue reading
VietNamNet Bridge – Minister of Planning and Investment Bui Quang Vinh has disagreed with the opinion that Coca-Cola has been conducting transfer pricing in Vietnam, affirming that the soft drink manufacturer is innocent until proven guilty. Vinh made the statement at the Vietnam Global Investment Forum held in Hanoi in… – Continue reading
Corporate income tax Italian corporate income tax (imposta sul reddito delle società, or IRES) is due by resident companies on their worldwide income. A company is deemed to be resident within the Italian territory when it has any of the following elements located in Italy for the major part of… – Continue reading
Remarkably on schedule, the OECD this week issued a comprehensive and integrated set of measures to attack base erosion and profit shifting (BEPS) on a global basis. Comprising 15 “Actions” on central issues such as transfer pricing, country-by-country reporting and transfer pricing documentation, treaty abuse, preferential tax regimes, permanent establishments,… – Continue reading
MTN Uganda has been accused of failing to provide evidence to justify shifting huge amounts of cash out of Uganda to a briefcase company located in Mauritius, potentially lowering its tax bill in Uganda – the subject of which remains an ongoing dispute with Uganda Revenue Authority, it has emerged…. – Continue reading
A quarter of companies say they won’t meet the first deadline proposed by the Organisation of Economic Co-operation and Development (OECD) in its base erosion and profit shifting (BEPS) action plan, reports Economia. Globally, 74 per cent said they will complete their country-by-country analysis by the first due date, December… – Continue reading
Singapore has given the thumbs up to an international plan that aims to clamp down on tax avoidance by multinational firms, reports the Straits Times. The Republic says if the plan is soundly implemented, it will help foster free and fair economic competition. Singapore agrees with the main principle of… – Continue reading
The global war on corporate tax avoidance doesn’t look like being so gruesome after all. The OECD reckons that governments are losing out on at least €213bn per year from aggressive tax planning by multinationals, reports the Irish Independent. A new book by a Berkeley University economics professor estimates that… – Continue reading
The Common Consolidated Corporate Tax Base is strongly opposed by Ireland The European Commission has opened a public consultation into its proposed scheme for a Common Consolidated Corporate Tax Base (CCCTB) ahead of its planned re-launch next year. The EU’s executive arm is seeking insights from stakeholders by January 8th… – Continue reading
Senior tax executives are preparing for changes in the tax landscape as a result of the Organization for Economic Co-operation and Development’s base erosion and profit shifting project. A new survey by Ernst & Young, presented Thursday at its 34th Annual International Tax Conference, found 88 percent of tax directors… – Continue reading
On 5 October 2015, the Organisation for Economic Co-operation and Development (OECD) issued a final package of reports in connection with its Action Plan to address Base Erosion and Profit Shifting (BEPS), as well as a plan for follow-up work and a timetable for implementation. The OECD’s BEPS Action Plan,… – Continue reading
Government should look to the example set by Barbados and start charging Value Added Tax (VAT) on betting and gaming activities in Trinidad and Tobago. This was the advice coming from Tax Director of KPMG’s TT operations, Nicole Joseph, during a post-budget forum hosted by the American Chamber of Commerce… – Continue reading
The court overruled the order of Income Tax Appellate Tribunal issued last year suggesting that the income tax dept has jurisdiction in this dispute Mumbai: The Bombay high court on Thursday ruled in favour of the Indian arm of Vodafone Group Plc. in a Rs.8,500 crore transfer pricing tax dispute…. – Continue reading
On October 5, 2015, the OECD released its final reports relating to the OECD/G20 base erosion and profit shifting (BEPS) project (the Final Reports). The BEPS project began in 2013 and has received unprecedented attention from governments and the private sector. The Final Reports outline the OECD’s recommendations and the… – Continue reading
A financial adviser and a group of film producers who set up an international scheme are facing a trial for fraud. It is alleged the scheme, which took advantage of the tax relief the UK Government offers the film industry, created the appearance of huge “paper losses”, The Times reported… – Continue reading
The proposals are aimed at preventing aggressive tax planning by multinationals. However, experts warn that the risk of double taxation may increase. SINGAPORE: Tax experts have said that Singapore’s tax jurisdiction is broadly in line with new tax proposals announced on Monday (Oct 5) by the Organisation for Economic Co-operation… – Continue reading
Supporters of a plan to tax overseas profits to pay for U.S. transportation projects said Wednesday the proposal is the “only possible path forward” for passing a highway bill in the House this month. The sponsors of legislation in the House containing the offshore taxes-for-roads proposal said the plan, known… – Continue reading
The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading
On 6 October 2015, the Council of the European Union reached agreement on a proposal for a Council Directive (‘the New Directive’) amending Directive 2011/16/EU (Directive on administrative cooperation between Member States) and requiring automatic exchange of information on ‘advance tax rulings’ (‘Tax Rulings’) and ‘advance pricing arrangements’ (‘APAs’) between… – Continue reading
For many years international tax planning for Russian inbound and outbound investments, and wealth planning for Russian resident individuals, was rather straightforward. That was primarily due to relatively simple domestic tax rules and a degree of inexperience amongst the Russian tax and other interested authorities in relation to international tax… – Continue reading
With the bulk of the OECD’s work on the BEPS project complete, attention will now turn to the implementation of the recommendations by member countries and others. Minister for Finance, Michael Noonan said that he welcomed the Base Erosion and Profit Shifting (Beps) report, and that the OECD’s proposals would… – Continue reading
Oct. 6 (BusinessDesk) – Fonterra Cooperative Group is likely to be among some 20 New Zealand companies left dealing with increased red tape to comply with wide-ranging reforms to corporate tax rules proposed by the Organisation for Economic Cooperation and Development and expected to be endorsed by the world’s 20… – Continue reading
The OECD-G20 plan to stop multinational tax avoidance could put companies in the middle of border disputes between revenue authorities, tax experts have warned. But civil society groups say the plan has not gone far enough and could make it easier for some multinationals to dodge tax. Treasurer Scott Morrison… – Continue reading
One-quarter of corporate tax and transfer pricing directors surveyed say their companies will fail to meet the first deadline proposed by the Organisation for Economic Co-operation and Development (OECD) in its Base Erosion and Profit Shifting (BEPS) Action Plan. Finance ministers for the G20 countries called on the OECD to… – Continue reading
Minister of State for Finance Simon Harris claims Ireland’s corporation tax regime is transparent and robust Ireland’s corporation tax regime is transparent and robust, Minister of State for Finance Simon Harris has insisted. He told the Dáil the State believed a multilateral response was the right response to aggressive tax… – Continue reading
LUXEMBOURG: European Union finance ministers agreed on Tuesday to automatically exchange information on deals struck with multinational companies from 2017 in a bid to reduce tax avoidance, officials said. “We have a political deal on this issue,” Luxembourg’s finance minister Pierre Gramegna told his EU counterparts in a public session… – Continue reading
LONDON (CNNMoney) — Bermuda, the Cayman Islands and the British Virgin Islands are more than just sunny vacation spots. They’re also three of the biggest tax havens for U.S. companies, according to a report from the left-leaning Citizens for Tax Justice and the U.S. Public Interest Research Group. The islands… – Continue reading
Last year at this time, news about “tax inversions” was grabbing headlines – cases where large U.S. multinationals would buy a foreign company in a tax-friendly jurisdiction, and then relocate its headquarters to reap the tax arbitrage benefits. The Obama administration responded to the rash of high-profile inversions with new… – Continue reading
Senior EY partners Andy Archer and David Snell look at some looming changes to international tax rules. In what will be the biggest change to the international tax rule book since it was put in place before World War 2, the OECD will tomorrow (4 am Tuesday 6 October) release… – Continue reading
Daily Herald Reports Specialty drug manufacturer Horizon Pharma, which moved its corporate headquarters from Deerfield to Ireland in 2014, announced it is relocating its U.S. headquarters from Deerfield to Lake Forest as part of a company expansion. The Dublin-based company reported it signed a long-term sublease on a 160,000-square-foot building… – Continue reading
With the final draft of the OECD’s BEPS initiative – Base Erosion and Profit Shifting – out later today, the taxman’s ability to tax international transactions as well as those of foreign firms operating in India will go up dramatically; the idea behind the initiative is to treat all cross-border… – Continue reading
The Organization for Economic Cooperation and Development on Monday rolled out a sweeping set of final recommendations to battle offshore tax avoidance costing countries across the globe billions of dollars a year. A group of almost three dozen advanced economies, the OECD kicked off its efforts two years ago, seeking… – Continue reading
Europe’s stiff-neckedness is difficult to cure. To come to an agreement for supranational treatment of a certain issue there needs to be a large cataclysm or at least a large scandal. In the case of taxation policy the problem begins to gain urgent and most importantly European status after the… – Continue reading
Pharmaceuticals group defends use of legal avoidance scheme, after paying no UK corporation tax over two years despite global profits of £3bn AstraZeneca, one of Britain’s largest businesses, is using a multimillion-pound tax avoidance scheme in the Netherlands, set up months after the UK relaxed its tax laws for multinationals… – Continue reading
New Delhi, Oct 4 (PTI) Legacy tax issues like those involving Cairn and Shell can be referred to AP Shah panel for quick resolution, says Chief Economic Advisor Arvind Subramanian who feels the old issues that have held back private investments also need to be worked out. Moving to defuse… – Continue reading
The OECD’s measures to reform international corporate tax systems will cause Ireland fewer problems than forecast, but for eurozone countries it will be just the beginning of greater and more detailed change. Following two years of constant meetings between tax experts from its 34 country members, the Paris-based body releases… – Continue reading
On Monday (5 Oct) the Paris-based Organisation for Economic Cooperation and Development (OECD) will present its final Base Erosion and Profit Shifting (Beps) project corporate tax reform proposals and on Tuesday the Ecofin council of EU finance ministers, is expected to agree on the exchange of tax rulings between member… – Continue reading
On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under section 482 of the Internal Revenue Code that says taxpayers have to take into account, among other costs, the costs of stock-based… – Continue reading
An offshore bank account is a must for many internationally mobile expats operating in the UAE and Middle East. But finding the right bank with the right extras as well as high service standards isn’t easy. There are plenty of big names to choose from, including the global operators Barclays,… – Continue reading
On September 18, 2015, the Danish Ministry of Taxation published draft legislation to introduce a new country-by-country reporting obligation for multinational corporations. The draft Bill would introduce the new three-tiered approach to transfer pricing documentation that is to be proposed formally by the OECD as part of the BEPS deliverables… – Continue reading
