The 4,029-page tax code is so complex both parties want to revise it. On business tax reform, they share surprising common ground, raising the potential for partial tax reform to be enacted this year. As the 114th Congress convenes this week, it has a golden opportunity to rid itself of… – Continue reading
The Inland Revenue Authority of Singapore (IRAS) has published an updated consolidated e-Tax Guide on the country’s transfer pricing regime. The e-Tax Guide, which was released on January 6, 2015, is divided into three main parts. Part I of the Guide provides background on the treatment of related-party transactions and… – Continue reading
THE South African Revenue Service (SARS) has already begun to tackle the erosion of the tax base through profit shifting, which was addressed in an interim report of the Davis tax committee that was released last month for public comment. SA loses billions of rand in revenue annually through the… – Continue reading
New research shows that 2014 saw many fundamental changes across the global tax system as governments look to reform their regimes for the long term, complying with new OECD guidelines, whilst significantly clamping down on multinationals in light of increasing public media scrutiny. The research was undertaken by Taxand, a… – Continue reading
The Federal Board of Revenue (FBR) is planning to introduce amendments to the income tax law in next federal budget (2015-16) to effectively deal with the transfer pricing issues of non-resident companies. Sources told Business Recorder on Monday that the first meeting of the FBR’s transfer pricing unit would be… – Continue reading
The Federal Board of Revenue (FBR) is planning to introduce amendments to the income tax law in next federal budget (2015-16) to effectively deal with the transfer pricing issues of non-resident companies. Sources told Business Recorder on Monday that the first meeting of the FBR’s transfer pricing unit would be… – Continue reading
TWO noteworthy taxation amendments came into effect on the 1st of January 2015. The first tax amendment relates to the deductibility of interest paid to a person who is not liable to tax in South Africa, for example non-residents. The section in question, section 23M of the Income Tax Act,… – Continue reading
Multinational enterprises (MNEs) may be concerned about various aspects of the six Discussion Drafts released during the third week of December 2014 as part of the Base Erosion and Profit Shifting (BEPS) Action Plan. Three of the papers are within Action items 8 to 10 of the BEPS Action Plan… – Continue reading
Medtronic Inc. took one step closer to becoming an Irish company when shareholders voted in favor of acquiring Dublin-based medical supply maker Covidien Ltd. Covidien shareholders similarly voted on the deal early today and also approved it. The acquisition now goes before the Irish High Court, which may take several… – Continue reading
As the Organisation for Economic Co-operation and Development (OECD) passes the halfway point in its joint project with the G20 to address base erosion and profit shifting (BEPS) concerns, it is worth pausing to examine what the consequences of some of the proposed changes may be. Much of the focus… – Continue reading
The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing. The link below is to a video summary of the predicted consequences of… – Continue reading
Trusts established by Portuguese resident individuals are now to be taxed for the first time after new rules were introduced on 1 January. On 17 December last year, the Government of Portugal introduced a change to its tax law meaning distributions from trusts to Portuguese residents would be taxed at… – Continue reading
Multinationals told to be more cautious about intra-group transactions as Beijing imposes stiff measures against avoidance and evasion Multinationals have been advised to take notice of Beijing’s New Year resolution to crack down on tax avoidance and evasion, especially after the announcement of the general anti-avoidance rule (GAAR) and new… – Continue reading
New Delhi: As a probe continues into misuse of stock markets for routing black money and tax evasion, the regulatory and other agencies suspect that GDR route is being used for bringing back suspected illicit funds stashed abroad. The modus-operandi, in cases currently under scanner, involves an intricate web of… – Continue reading
Will a person working both in India and outside for a certain time be taxed in both the countries or is there any tax regulation present. Indians have become accustomed to taking up jobs outside India as an offshore assignment or project. That means spending some part of the year… – Continue reading
The Price of Offshore Revisited was written by James Henry, a former chief economist at the consultancy McKinsey, for the Tax Justice Network. Tax expert and UK government adviser John Whiting said he was sceptical that the amount hidden was so large. Mr Whiting, tax policy director at the Chartered… – Continue reading
Europe’s tax showdown could be headed straight to people’s wallets. With the new year, a change in fiscal rules in the European Union is increasing the tax on many purchases of digital content like e-books and smartphone applications. Under the new rules, first approved in 2008, the tax rate on… – Continue reading
Critics said the deal would allow Medtronic avoid taxes while providing preferential treatment to executives. The promise of 1,000 new Minnesota jobs was not enough to convince the state’s pension board to support a $48 billion corporate transaction that will move Medtronic’s legal headquarters overseas. A four-member subcommittee of the… – Continue reading
NEW DELHI, JANUARY 2: The dispute resolution mechanism for matters relating to international tax and transfer pricing has been streamlined. The Finance Ministry has put in place a new framework that seeks to bring much-needed rigour and neutrality to dispute resolution on international tax issues. The move should encourage multinationals… – Continue reading
The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then hastingly signed by President Putin in the time span of a week and a half, comes into force on January 1, 2015. The new deoffshorisation legislation that passed with lightning speed through Russia’s Parliament and then… – Continue reading
BRUSSELS – As political honeymoons go, it was short and ended abruptly. Just one week into his job as European Commission president, Jean-Claude Juncker was broadsided by a series of newspaper articles outlining the depth and breadth of corporate tax avoidance schemes in Luxembourg. Schemes thought up and enacted while… – Continue reading
CMS Bureau Francis Lefebvre, a leading French law firm, has noted that the 2015 Finance Act and the Rectificative Finance Act for 2014 were adopted by the French Parliament on December 18. Certain provisions have been reviewed by the Constitutional Court, which issued its ruling on December 29. Both laws… – Continue reading
Once a niche proposal, the recent public focus on corporate tax avoidance has sparked real interest in the idea of eliminating corporation tax altogether. Surprisingly, the statistics suggest that employees and other stakeholders may also benefit from this In winter 2012, hundreds of activists packed inside their local Starbucks after… – Continue reading
In recent court filings made in various federal district courts in Washington and California, the Internal Revenue Service is seeking to enforce testimonial summonses issued to current or former Microsoft employees, including former CEO Steven A. Ballmer. The summons had been issued earlier this fall. Microsoft’s outside tax counsel responded… – Continue reading
A withholding tax is a tax that is kept back from an employee’s salary and subsequently paid directly to the government. Withholding taxes are commonly employed by countries throughout the world to help combat tax evasion. Countries in Asia typically divide withholding tax into dividends, interest and royalties payments, with… – Continue reading
The transfer pricing department is yet to make adjustments on share issuances by Vodafone India services to Vodafone Teleservices Mauritius for assessment year 2011 and 2012. The transfer pricing department has sought clarity from the government on legal recourse in the Vodafone transfer pricing case. Sources have indicated that the… – Continue reading
CAPE TOWN — South Africa needs to finalise the renegotiation of its tax treaty with Mauritius as soon as possible to prevent the loss of large sums of money through “treaty shopping” the Davis tax committee has urged. The committee released its interim report on ways to prevent base erosion… – Continue reading
Currently, there is a tendency among those who take an interest in international tax developments to look to the future and try to guess how the international tax landscape will look in, say, three of four years, once countries begin to implement the OECD’s base erosion and profit shifting (BEPS)… – Continue reading
Fiat Chrysler Automobiles publicly denied a media report saying it was thinking about moving the tax residence of its Ferrari luxury sports car division outside Italy. “These rumors have no grounds,” FCA said in a company statement. “There is no intention to move the tax residence of Ferrari SpA outside… – Continue reading
The OECD is urging governments to tackle interest payments made by multinationals and their subsidiaries as part of a global crackdown on profit shifting. The aim is to also stop companies artificially loading debt in no-tax or low-tax jurisdictions to reduce their tax bills. It comes as the government backs… – Continue reading
The courtroom victory of the only Swiss banker to beat the U.S. in a trial over offshore tax evasion may embolden other indicted financial workers to leave a legal limbo some have endured more than five years. Twenty-five offshore bankers, lawyers and advisers have yet to answer U.S. Justice Department… – Continue reading
KPMG has responded to the ATO’s recent taxation ruling TR 2014/8 (documentation requirements) and practice statements PSLA 2014/2 (penalties) and PSLA 2014/3 (simplification). Anthony Seve, KPMG transfer pricing partner, said the ruling places increased compliance and documentation obligations on larger companies. This, he said, is reflective of global developments. “Although… – Continue reading
The Internal Revenue Service has sued former Microsoft CEO Steve Ballmer and a slate of other former and current executives, seeking to compel them to testify in a long-running investigation into how the company’s sales through subsidiaries affected its taxable income. The Internal Revenue Service has sued former Microsoft Chief… – Continue reading
Japan has remained a cornerstone of Pakistan’s economy for the past many years. Japanese Companies have invested in all sectors across Pakistan. Be it auto, trading, manufacturing, infrastructure development, packaging, steel manufacturing, indenting, etc a large number of Japanese Companies have a strong presence in Pakistan. Pakistan’s Investment and Corporate… – Continue reading
The Federal Board of Revenue (FBR) has constituted a transfer pricing unit to enhance the capacity of the tax officials to effectively deal with the transfer pricing related issues. According to a notification issued by the FBR here on Monday, a transfer pricing unit is set up at the FBR… – Continue reading
In August, President Barack Obama pledged to use the powers of his office to discourage the corporate tax-avoidance technique known as inversion, in which U.S. companies claim foreign tax addresses. Four months earlier, according to a previously unreported legal document, his Department of Homeland Security did just the opposite. It… – Continue reading
*Ernst & Young LLP, New York, NY The BEPS beat plays on. Congratulations to the OECD for meeting (mostly) the ambitious goals for release of their reports on seven action items in September 2014 – right on schedule on September 16. The documents released on September 16 relate to Action… – Continue reading
More countries are requiring an exchange of client information In 2014, we saw a marked increase in transparency regarding foreign assets. The United States took the lead, and other countries followed suit. It looks like we’ve reached the tipping point, that is, “the magic moment when an idea, trend, or… – Continue reading
Mumbai: In its biggest ever crackdown for suspected tax evasion and laundering of black money through stock trading platforms, Sebi Friday barred 260 entities, including individuals and companies, from the securities markets. While Sebi would further probe these cases, it has also decided to refer the matter to the Income… – Continue reading
The CBDT has signed its first bilateral advance pricing agreement or APA with Japan. The APA regime was introduced in 2012 and it allows taxpayers and tax authorities to determine in advance, an appropriate transfer pricing methodology for a given set of transactions. Payaswini Upadhyay has the exclusive details. The… – Continue reading
The Qatari ruling family has been ordered to pay £38million in stamp duty They used an aggressive tax avoidance scheme to avoid the huge bill Country bought 13-acre site from the MoD for almost £1billion in 2007 By LOUISE ECCLES, BUSINESS CORRESPONDENT FOR THE DAILY MAIL PUBLISHED: 01:57 GMT, 20… – Continue reading
Ambassadors are supposed to be diplomatic and suave. Yet even those of the diplomatic corp may occasionally get tongue-tied or utter ill-timed statements. Take U.S. Ambassador to Britain Matthew Barzun. He recently sounded not all that diplomatic about duty, compliance with law, and yes, even taxes. Lee Rigby was a… – Continue reading
Burger King Chief Executive Officer Daniel Schwartz swears that the company’s plan to renounce its U.S. “citizenship” and become a Canadian corporation “is really not about taxes.” But a new report by my group, Americans for Tax Fairness, finds that it really is about taxes after all. The report reveals… – Continue reading
Debate on multinational tax avoidance widens The surprise announcement by the European Commission that it is to extend its request for information on tax rulings to all European Union member states has the potential to significantly shift the terms of the debate on multinational tax avoidance. The timing of the… – Continue reading
The amendments to the Tax Code of Ukraine, proposed in the draft law on improving tax control on transfer pricing, bring the Tax Code in line with the requirements of the Organisation for Economic Co-operation and Development (OECD) on transfer pricing for multinational companies and tax services. According to a… – Continue reading
The total number of reports on controlled transfer pricing operations, received by the State Fiscal Service of Ukraine, as of October 1, 2014 exceeded 2,500. The head of the department for transfer pricing inspections at the Fiscal Service, Mykola Mishin, said at the round table “Transfer pricing in Ukraine: problems… – Continue reading
Transfer pricing has been an area of high importance for years. We are seeing that multinational companies operating in Germany are being increasingly examined by tax auditors. The level of transfer pricing expertise of the tax auditors is also increasing. Therefore, the transfer pricing environment in Germany is getting more… – Continue reading
“These measures were taken in line with the policy announced by President Vladimir Putin for the Russian economy’s de-offshorization,” USM Holdings owned by billionaire Alisher Usmanov said MOSCOW, December 19. /TASS/. USM Holdings owned by billionaire Alisher Usmanov is transferring key assets to Russian holding companies, USM said in a… – Continue reading
This is going to be the plum job for any international tax practitioner: Competent Authority for the Republic of Ireland. It seems pretty clear that the Base Erosion and Profit Shifting (BEPS) project will meet its announced deadline of the end of 2015 to produce final reports on all of… – Continue reading
Five Senate Democrats urged the IRS to put harsher rules into place to stop the offshore tax deals known as inversions. The five Democrats said the recently finalized deal between Burger King and the Canadian doughnut chain Tim Hortons – perhaps the most prominent in the recent wave of cross-border… – Continue reading
