NEW DELHI: The finance ministry, seeking to build on the recent success in pitching India as an attractive destination, is looking at burying for good the remaining high-profile acrimonious tax tangles involving Cairn India and Royal Dutch Shell, which have tarnished the country’s administration. North Block is likely to replicate… – Continue reading
Donald Trump’s tax plan was revealed with a message for millions of Americans: “You win!” But like everything linked to taxes, not everyone would win equally under his plan, which the Republican presidential candidate says is geared toward providing tax relief for the middle class and giving the U.S. economy… – Continue reading
The OECD/ G20 Action Plan on Base Erosion and Profit Shifting (BEPS) published in July 2013, identifies 15 actions to address BEPS in a comprehensive manner. Actions 8-10 of the BEPS Action Plan relate to a number of closely related topics. These include the development of rules to prevent BEPS… – Continue reading
The tax authority has moved to compile a statement of international transaction (SIT) for the first time by collecting details of all of the cross-border financial transactions conducted by the taxpayers across the country. The Income Tax wing under the National Board of Revenue (NBR) has taken the initiative to… – Continue reading
At least 25 multi-millionaire Canadians used an offshore “sham” set up by accounting firm KPMG, a document filed Tuesday in Federal Court shows. For more than two years, KPMG has been fighting a court order to provide the list of names of multi-millionaire clients who had used what the CRA… – Continue reading
Tax laws are lagging behind the digital economy. As changes in the digital realm continue to outpace the speed at which legislators can work, and borders increasingly blur because of the internet, SA needs to play catch-up when it comes to tax. Currently, the only digital tax of any consequence… – Continue reading
Moving overseas to cut tax burden remains a viable option for some firms, though the presidential candidates may have other plans. With the long haul of a presidential election campaign just beginning, companies that leave the U.S. to lower their tax bills are once again political targets. Donald Trump this… – Continue reading
Ruling description In thejudgment of August 19, 2015 (case file no. II FSK 1747/13) the Supreme Administrative Court ruled, consistently with its previous rulings, that in the case of a transfer of shares for redemption at a remuneration lower than their market value, the tax authorities do not have the… – Continue reading
In light of the global Base Erosion and Profit Shifting (BEPS) initiative and the European developments against tax evasion and aggressive tax planning, two European Directives were adopted in July 2014 and January 20151 by the European Council, amending the Parent-Subsidiary Directive (2011/96/EU). These two Directives, in a nutshell, aim… – Continue reading
Tax havens are by design secretive and opaque. The entire point of their existence is to conceal the wealth hidden within them. And a new book by Gabriel Zucman, The Hidden Wealth of Nations: The Scourge of Tax Havens, reveals, as never before, the extent of their role in the… – Continue reading
The OECD has said that its base erosion and profit shifting (BEPS) project will create policy challenges for Ireland, but the nation should emerge well placed to attract foreign direct investment, reports Tax News. The report states: “Given the strong presence of intellectual property-intensive information technology and pharmaceutical companies in… – Continue reading
China’s State Administration of Taxation (SAT) has been busy during recent months pushing ahead with its own plans to update/revise a series of domestic tax laws and regulations as well as Sino-foreign tax treaties. The most prominent of these changes is a proposed update of Circular Guoshuifa 2009 No.2 (Circular… – Continue reading
If you are a foreign executive moving to the United States for work, not only do you have to consider practical concerns like moving your family and finding a new residence, but you also need guidance as to any US tax implications stemming from the move. One of the first… – Continue reading
Efforts to amend details of new rules on corporate profits raise questions, reports the Wall Street Journal. Nearly 50 governments are set to agree this fall to a new set of rules to clamp down on tax avoidance among multinational corporations. Their chance of success, however, is unclear. If the… – Continue reading
If the anti-corruption march goes ahead on Wednesday, it will be remiss if it doesn’t address one of the key issues of 2015: illicit financial flows. Institutions around the world are committing to combatting these and Unite Against Corruption needs to push the government to take action locally while lobbying… – Continue reading
MBABANE – City Press has alleged that the Swazi government has been robbed of billions of Emalangeni in the mining deal of iron ore at Ngwenya mine as the funds were siphoned off to the Seychelles in an abusive transfer pricing scheme. Financial statements of Shanmuga Rethenam’s companies have revealed… – Continue reading
The Base Erosion and Profit Shifting (BEPS) Action Plan adopted by the OECD and G20 countries in 2013 recognised that enhancing transparency for tax administrations by providing them with adequate information to assess high-level transfer pricing and other BEPS-related risks is a crucial aspect for tackling the BEPS problem. Against… – Continue reading
On September 17, 2015, the Canadian Border Services Agency (“CBSA“) released a revised D-Memorandum D13-4-5, “Transaction Value Method for Related Persons” (the “Memorandum“), addressing the impact of income tax transfer pricing on the value for duty to be declared on goods imported into Canada. This new guidance will have a… – Continue reading
India must align domestic laws with international treaties A recent ruling of the Punjab & Haryana High Court (HC) in the Serco BPO case has once again underlined the need for consistency between tax policies and the jurisprudence that evolves around it, thus, leaving little to interpretational hazards. The HC,… – Continue reading
Reading companies’ annual reports to the Securities and Exchange Commission is a reliable cure for insomnia. Every so often, though, there is a significant revelation in the paperwork. Last year, one of the most important revelations came from Microsoft’s filings, which spotlighted how the tax code allows corporations to enjoy… – Continue reading
TORONTO (miningweekly.com) – The world’s largest precious metals streaming firm Silver Wheaton is set to challenge the Canadian Revenue Agency (CRA) over the agency’s decision to reassess the company’s 2005 to 2010 tax years and collect taxes on income earned by Silver Wheaton’s offshore subsidiaries. The TSX– and NYSE-listed company,… – Continue reading
Automatic exchange of information for tax law enforcement purposes started first in Europe with the EU Savings Tax Directive, went international with the US Foreign Accounts Tax Compliance Act, and, from 2017, will go global with the recently-agreed Common Reporting Standard, the subject of this feature. Introduction To The Common… – Continue reading
Content supplied by EY New Zealand is one of only a few countries with a dividend imputation regime. Introduced in 1988, New Zealand’s imputation regime removes double taxation on distributions by attributing to shareholders a credit for the tax borne on profits at the company level. Benefits include a single… – Continue reading
Bloomberg BNA’s first transfer pricing conference in Asia—the latest offering in our Global Transfer Pricing Conference series with Baker & McKenzie—could not have been better timed. The day the conference opened, Sept. 17, China issued a revised draft circular on transfer pricing that completely changed the game for multinational companies… – Continue reading
Myanmar plans to introduce more laws and regulations to increase its tax income over the coming years, sources said. The Internal Revenue Department (IRD) currently sets polices under the Myanmar Tax Law and the Union Tax Law. Sources at the IRD said they will issue further notifications, if required, to… – Continue reading
Tax avoidance is a key problem for European countries, with the EU taking several steps to try and limit the ability of businesses to shift their profits to low-tax jurisdictions. Peter Dietsch writes on the nature of the problem and what can be done to tackle it. He argues that… – Continue reading
Tax competition as such cannot be avoided, but today’s system has reached its limits and led to unwanted side effects. Small firms should not have to bear the tax burden of multinationals that pay very little. Action is needed to harmonise corporate tax practices across Europe, so as to make… – Continue reading
The IRS recently replaced Rev. Proc. 2006-54 for requesting assistance under the Mutual Agreement Procedure (“MAP”) article of U.S. tax treaties, and Rev. Proc. 2006-9 for requesting Advance Pricing Agreements (“APAs”). The new Rev. Procs. (2015-40 and 2015-41, respectively) largely track draft procedures issued in 2013 (Notices 2013-78 and 2013-79),… – Continue reading
Action is needed to harmonize corporate tax practices across Europe, according to the European Parliament’s Special Committee on Tax Rulings. The committee said this was the key sentiment voiced during a meeting with finance ministers from Luxembourg, Italy, France, Spain, and Germany on September 22. According to the committee, while… – Continue reading
Entebbe — Members of African Parliamentarian Network on Illicit Financial Flows and Tax (APNIFFT) want governments across the continent to put more pressure on multinational companies to pay full taxes. According to the parliamentarians, tax evasion and illicit financial flow (IFFs) from Africa can be brought to an end if… – Continue reading
Valeant is famous for wringing cost savings out of its buyouts, and its tax-advantaged Canadian domicile helps on that front. Now, it’s leveraging another address to pare down Salix’s tax bill by more than $560 million. But how? According to documents seen by The Wall Street Journal, the strategy used… – Continue reading
Finance ministers of euro zone’s major economies renewed on Tuesday their commitment to curb multinational corporations’ tax avoidance and called for more consistent rules to reduce “harmful” tax competition. Multinational companies have long been in the sights of European Union authorities because of the way they can legally reduce their… – Continue reading
BY DAVID JESSOP— The Caribbean has just 18 congressional working days from Sunday, September 20 to try to have the U.S. Congress address an act naming 17 Caribbean nations as “tax havens”. If passed without amendment, it could have the effect of reputationally damaging the countries concerned with unpredictable trade,… – Continue reading
Oil and gas multinational Chevron has come under fire in Australia for using Bermuda for tax avoidance. US-based Chevron, along with Anglo-Dutch firm Shell and the American ExxonMobil, is set to begin production at the massive Gorgon gasfield off the coast of Western Australia. But Chevron has been grilled by… – Continue reading
Coalition bill to scrap taxation transparency requirements for privately held companies with incomes of $100m or more examined in Senate hearing The Australian federal police had not been approached by the tax office over fears that publishing the tax details of wealthy individuals would lead to an increased risk of… – Continue reading
As discussed in the previous edition, due to current worldwide developments including the OECD’s move to curb tax Base Erosion and Profit Shifting (BEPS), tax policy is changing significantly. In Ghana for example, a Transfer Pricing Regulations was passed in 2012 which aimed to ensure that the tax base of… – Continue reading
The reality of preparing global documentation may be expanding from a process of producing one or a small number of clearly defined reports to one of collecting and managing potentially significant amounts of data. This article considers how processes and technology habits may need to change to react effectively to… – Continue reading
The Indian Government must assure investors that it is committed to improving its legal framework, including the tax code, if it is to meet its economic objectives, a senior US State Department official has said. Ahead of Indian Prime Minister Narendra Modi’s visit to the US this week, Nisha Desai… – Continue reading
Accounting firm joined revenue minister at speech while fighting court order Top Conservative cabinet ministers met publicly with senior staff from KPMG’s tax division, and one went so far as to promote the firm, even as the Canada Revenue Agency was alleging the company set up an offshore tax “sham”… – Continue reading
New Delhi, Sept. 20: A bilateral investment treaty between India and the US is unlikely to be finalised before Prime Minister Narendra Modi’s visit to America later this week. Both Modi and US President Barack Obama have been pushing their respective bureaucracies to prepare the pact. Modi will be in… – Continue reading
China’s State Administration of Taxation on 17 September 2015 released a discussion draft of proposed guidance relating to “special tax adjustments”—including those concerning transfer pricing—for public consultation. It is anticipated that this guidance could be finalized by the end of 2015, and once final, would replace the existing transfer pricing… – Continue reading
The Caribbean has just 18 congressional working days from Sunday September 20 to try to have the US Congress or the District of Colombia address an act naming 17 Caribbean nations as “tax havens”. If passed without amendment it could have the effect of reputationally damaging the countries concerned with… – Continue reading
Labour MEP warns that EU tax harmonisation against the interests of Malta and other European islands and peripheral regions Labour MEP and former Prime Minister Alfred Sant told the European Parliament that EU tax harmonisation goes against the interests of Malta and other peripheral regions and islands with limited endowments… – Continue reading
On Friday, Coca-Cola Co. said that it may owe the IRS an extra $3.3 billion in federal income taxes. According to the company, the Internal Revenue Service found after a five-year-long audit that the soft drink giant may owe the federal government $3.3 billion along with interest for the 2007… – Continue reading
Poland’s lower house (Sejm) on 11 September 2015 passed a bill containing amendments to the tax laws, including changes to the rules governing transactions between related parties—the transfer pricing rules. If enacted, the transfer pricing rules would be effective 1 January 2017. Among the legislative changes, new rules would: Increase… – Continue reading
Speed read On 15 September 2015 the Dutch government published its Tax Plan 2016. In this e-alert we discuss the legislative proposals in the Tax Plan which are of interest for companies. 1 INTRODUCTION Today, the Dutch Ministry of Finance published its Tax Plan 2016. In fact, the government sent… – Continue reading
On 16 September 2014, the OECD released the report on the tax challenges of the digital economy (the “Report”) under its Action Plan on Base Erosion and Profit Shifting (“BEPS”). The Report recognises that because the digital economy is increasingly becoming the economy itself, it would be difficult, if not… – Continue reading
The 2016 Mexican Economic Package includes a proposal for country-by-country (CbC) reporting of tax information by certain multinational corporations. The Package, which was submitted to Congress by the Government on September 8, 2015, seeks to bring Mexican transfer pricing documentation rules into line with the Organisation for Economic Co-operation and… – Continue reading
Through Wetsvoorstel Overige Fiscale Maatregelen 2016, released on September 15, the Netherlands has confirmed the introduction of a new country-by-country (CbC) reporting obligation for multinational corporations. These regulations provide for the implementation of the recommendations of the Organisation for Economic Co-operation and Development (OECD) on transfer pricing documentation under Action… – Continue reading
Past Progress and Prospects Harmful tax practices (e.g., tax havens, preferential tax regimes, tax rulings) are characterised by the propensity to erode tax bases of other countries which allegedly leads to an undesirable race-to-the-bottom on taxation rates. Action 5 of the OECD Action Plan on Base Erosion and Profit Shifting… – Continue reading
