Commissioner-General of the Guyana Revenue Authority (GRA), Godfrey Statia warned Guyanese businessmen against offshore tax evasion, saying that global systems are being increasingly networked to weed out tax cheats and report them to their home-countries. Addressing a luncheon organised by the Guyana Manufacturing and Services Association (GMSA) at the Georgetown… – Continue reading
Forming a small insurance company known as a microcaptive can be a great way for small businesses to reduce insurance costs and realize tax savings. Abusive microcaptive arrangements, however, have attracted scrutiny from Congress and the IRS. Last month, the Tax Court decided an important microcaptive case, holding against the… – Continue reading
The Inter-American Center of Tax Administration (CIAT) has released a new statement summarizing the feedback from Latin American and Caribbean countries from ongoing discussions on countering base erosion and profit shifting. CIAT said it and a number of regional and international organizations have brought together policymakers from countries in the… – Continue reading
Solicitors providing tax planning services could face greater scrutiny from the Solicitors Regulatory Authority (SRA) and HMRC as government begins to clamp down on aggressive tax avoidance schemes The SRA has expressed its concerns that avoidance schemes previously deemed legitimate may no longer be accepted by HMRC. Solicitors and firms… – Continue reading
BHP is willing to head to court to fight the Australian Taxation Office on a more than $1 billion tax bill over its Singapore marketing hub. The world’s largest miner has continually defended its Singapore marketing hub, where it is accused of routing profits, and says it is confident of… – Continue reading
Appropriate Use of Country-by-Country Reports The OECD has now published Guidance (available here) on the appropriate use of Country-by-Country Reports (‘CbCRs’) by national tax authorities. This is in response to some valid MNE concerns that tax authorities may misuse CbCRs. “Appropriate use” is clarified as being for (i) high-level transfer… – Continue reading
Japanese multinational companies worry that filing their first country-by-country reports in 2018 will lead to a barrage of transfer pricing audits by developing countries. Companies are currently preparing their first country-by-country reports that must be filed with the National Tax Agency by the end of March 2018. Japan adopted country-by-country… – Continue reading
Ireland’s Minister for Finance (the “Minister”) welcomed the results of the independent review of Ireland’s corporation tax regime (the “Review”) issued on 12 September 2017: “I welcome the emphasis given in the Review to the importance of certainty, which is core to our corporate tax offering. Our 12.5% corporation tax… – Continue reading
…as tax dispute escalates Vodafone Ghana has filed a motion at the High Court of Justice, Commercial Division in Accra, against the Ghana Revenue Authority (GRA) disputing tax assessments of GH¢160 million, according to the Writ obtained by ghanabusinessnews.com. The GRA has asked Vodafone to pay 30 per cent of… – Continue reading
Changes in international tax laws spurred by the OECD’s BEPS project pose challenges for finance chiefs, but also offer some opportunities. The OECD’s base erosion and profit shifting (BEPS) project, with an overall goal of reducing global loss of tax revenues due to double non-taxation, has created the need for… – Continue reading
The Finnish Supreme Administrative Court published on 13 September 2017 precedent 2017:145 that further clarifies the scope of application of the Finnish transfer pricing adjustment provision (Act on Assessment Procedure (“AAP”) Section 31). In its previous landmark precedent KHO 2014:119 the Supreme Administrative Court stated that the so-called re-characterization of… – Continue reading
ECONOMYNEXT – Sri Lanka’s new tax law has provisions that more effectively block companies from trying to dodge taxes by using techniques like transfer pricing, an expert said. The Commissioner-General of Inland Revenue (CGIR) has been given the power to re-examine sch transactions if they are seen to have been… – Continue reading
The inexact science’ is regarded as the big culprit in reducing global companies’ tax exposure Tax collection from transfer pricing audits has become more common in Africa, with little sign that it will abate in the near future. The transfer pricing policies of many multinational companies have attracted widespread attention… – Continue reading
VAT is at the forefront of current tax reforms and soon to be a reality for many regional businesses, as it is expected to be introduced across the GCC from 1 January 2018. The GCC countries have signed up to a unified framework, which will form the basis of the… – Continue reading
Malawi’s recent budget included numerous tax changes and announced updates to the country’s transfer pricing rules. On the indirect tax front, the Budget, released in mid-August, introduced a 10 percent excise tax on television subscriptions and introduced a value added-tax exemption for dairy products, animal or vegetable fats and oils,… – Continue reading
MEDIUM and large businesses with multinational ties will soon have to start supplying the South African Revenue Service (SARS) with more detailed reports of their relationships and transactions with connected entities residing in other countries. SARS has beefed up its Transfer Pricing Division and is now actively involved in the… – Continue reading
The Federal Court of Canada has ruled that the Canadian Revenue Agency may not conduct further in-person interviews with representatives from a multinational corporation concerning its transfer pricing affairs, having already discussed earlier tax years. Cameco Corporation declined to produce approximately 25 personnel for oral interviews in relation to an… – Continue reading
African nations will have more resources at their disposal to meet the Sustainable Development Goals if their national revenue authorities can boost tax collection. The United Nations Economic Commission for Africa estimates that the continent loses more than $50 billion through illicit financial outflows per year, much of this linked… – Continue reading
PERTH (miningweekly.com) – US oil and gas major Chevron has withdrawn its High Court appeal over a A$340-million bill from the Australian Taxation Office (ATO). The withdrawal means that the Full Federal Court decision of April is now final. The company in May turned to the High Court after a… – Continue reading
Bizlive cited a report from the Foreign Investment Agency (FIA) as showing that the British Virgin Islands alone registered $1 billion worth of FDI in the first seven months of the year, raising its total accumulative investment capital to $21.4 billion, ranking fifth among countries and territories with the highest… – Continue reading
The Budget Advocacy Network (BAN) has called on the country’s revenue authority to push for better taxation not more taxation. In its Transfer Pricing Report, BAN identified that such efforts hold the potential to stimulate further growth and investment whilst also allowing for increased levels of tax collection. The huge… – Continue reading
On August 3, 2017, the Irish Revenue published Revenue e-Brief No. 74/17, which contains guidance for taxpayers on complying with Ireland’s transfer pricing documentation requirements. The guidance notes that companies are legally required to maintain transfer pricing documentation. However, there is no requirement for documentation to be kept in a… – Continue reading
APAs were recently implemented in the Croatian tax legislation. Our Transfer Pricing team briefly presents the main points of the Croatian legislation related to an APA. Transfer pricing legislation was introduced in Croatia by way of the Corporate Income Tax Act (CIT) on 1 January 2005. However, the Croatian tax… – Continue reading
Federal income tax reform is by far the biggest concern of corporate tax executives, a new survey from Bloomberg BNA reveals. Survey of Corporate Tax Departments 2017 spotlights several key tax issues, and “corporate tax professionals are facing a wealth of challenges as they look to prepare their businesses for… – Continue reading
Labour is threatening to crack down on multinational companies that are dodging paying their fair share of tax in a move it believes will net $200 million a year in extra tax for the Government. Leader Andrew Little said according to Inland Revenue, New Zealanders were missing out by hundreds… – Continue reading
The European Commission launched legal proceedings against Portugal, Bulgaria, and Cyprus for not adopting, in their national laws, European Union legislation requiring all EU countries to exchange tax rulings granted to multilateral companies. The legislation was adopted in the wake of the 2014 LuxLeaks scandal that revealed more than 100… – Continue reading
Senator Orrin Hatch (R – Utah) has said that lowering the United States’ corporate tax rate to one of the lowest in the world should be a top priority in current tax reform efforts. The Chairman of the Senate Committee on Finance said that the US corporate rate, one of… – Continue reading
The Australian Tax Office is preparing to take several companies to court over abuse of thin capitalisation rules and will start a wave of audits of large multinationals with complex cross-border loans, as it continues to take a hardline approach in the wake of its win against Chevron. The ATO… – Continue reading
Irish Finance Minister Paschal Donohoe has explained the country’s approach to tax evasion during a hearing of the European Parliament’s PANA Committee, and said Ireland is “a strong supporter of international tax reform efforts.” Donohoe was one of several European finance ministers who appeared before the committee on July 11…. – Continue reading
As of 1st July 2017, the tax treatment of intra-group financing arrangements has been amended in Cyprus. Intra-group financing transactions refers to finance activities between related parties (as defined in Section 33 of the Income Tax Law), including permanent establishments in Cyprus. Based on the Interpretative Circular issued by the… – Continue reading
Among the products purchased by the Ministry are: Onesource Benchmark and Onesource TP Loan Module. Thomson Reuters and Ministry of Taxes of the Republic of Azerbaijan have signed an agreement under which the Ministry will use Thomson Reuters tax solutions aimed at implementing tax control in the sphere of transfer… – Continue reading
Slovakia is the first V4 country to sign the agreement on country-by-country reporting. Slovakia’s Financial Administration has obtained easier access to the information of US multinational companies. The representatives of Slovakia and the US signed a bilateral agreement on country-by-country (CbC) reporting on June 21, the TASR newswire reported. The… – Continue reading
Companies will have to disclose “uncertain” tax positions, including amounts disputed by the Australian Tax Office, under new accounting rules designed to increase information available to investors. Australia will adopt international accounting guidance with effect from 2019 that RSM Australia national technical director Ralph Martin said would result in some… – Continue reading
Who is required to file, how it should be filed and what is necessary to disclose. Several South African-based multinational companies have less than six months to prepare their country-by-country reports for exchange with other tax jurisdictions. Many have realised the magnitude of the information expected and have been setting… – Continue reading
Introduction Finance Act 2016 replaced the test for corporate residency of foreign companies from “control and management being situated wholly in India” to “place of effective management (POEM) in India”. POEM has been defined to mean a place where key management and commercial decisions that are necessary for conduct of… – Continue reading
Sri Lankan companies that violate transfer pricing rules can be fined up to two percent of the total value of transactions between related parties in case of non-disclosure of any required information under the new tax law. The new law also provides for the Commissioner-General of Inland Revenue to impose… – Continue reading
The OECD has released for stakeholders’ comments two new discussion drafts as part of its base erosion and profit shifting work. The first draft builds on the OECD’s final report on BEPS Action 7 (on preventing the artificial avoidance of permanent establishment status). The final Report on Action 7 of… – Continue reading
A. Introduction In February 2017 Cyprus Tax Department has announced that the current practice regarding profit margins between related Company loans will be abolished by the 30th June 2017. The announcement indicates that the minimum acceptable margins will apply up to 30th June 2017, and as from 1st July 2017… – Continue reading
New Delhi, June 19 (IANS) The Central Board of Direct Taxes (CBDT) on Monday said it has operationalised the provisions of secondary adjustment in transfer pricing. The Finance Act, 2017 with effect from April 1, 2018 provided for secondary adjustment by attributing income to the excess money lying in the… – Continue reading
India has, for long, been always regarded as the one of the most aggressive transfer pricing jurisdictions. To mend this image and reduce litigation, the government introduced various measures like Advance Pricing Agreements (APA), the safe harbour regime, risk-based selection of transfer pricing audit cases etc. While most of these… – Continue reading
President Donald Trump and Republican leaders in Congress will soon confront a complex challenge for tax reform: how to limit U.S. corporate tax avoidance schemes that take advantage of low tax rates in foreign countries. Congressional and administration staff have begun to examine options to address profit-shifting schemes that include… – Continue reading
HA NOI — Viet Nam’s long-standing efforts to tackle the practice of transfer pricing as a tax avoidance ploy have gained sharper legal teeth with a new decree. Transfer pricing is the pricing of goods, services and intangibles between related parties, like a parent company and its affiliates. Apart from… – Continue reading
YEREVAN, June 7. /ARKA/. In 2018, Armenian taxpayers will start submitting transfer pricing papers to tax agencies, Nerses Nersisyan, head of KPMG Armenia department in charge of tax and legal consulting, told journalists on Tuesday. In October 2016, he said, a new tax code was adopted in Armenia, in which… – Continue reading
The amount of disputed tax relating to the transfer pricing of the U.K.’s largest businesses has risen 60 percent in the past year, according to law firm Pinsent Masons. Her Majesty’s Revenue and Customs, the U.K.’s tax authority, is reviewing as much as 3.8 billion pounds ($4.9 billion) of large… – Continue reading
The Botswana Unified Revenue Service (BURS) says tax avoidance schemes such as transfer pricing, base erosion and profit shifting appear to be on the rise in the country. Transfer pricing is regarded as a tax avoidance scheme in which multinational corporations shift profits to low tax jurisdictions and avoid taxes… – Continue reading
As Rwanda continues to attract more foreign direct investments and multinational firms, the economy has seen a wave on new developments and trends in areas like taxation and licensing regime. On the issue of taxation, it is important for the country to implement a transfer pricing policy as matter of… – Continue reading
Finance Minister Arun Jaitley will travel to Paris next week to sign the OECD multilateral convention that aims to check crossborder tax evasion by multinational companies. During his three-day visit beginning June 7, Jaitley will also attend the OECD Ministerial Council meeting, in which ministers from the OECD and partner… – Continue reading
The agreed rules will stop companies from escaping tax by exploiting the mismatches between Member States’ and non-EU countries’ tax systems (“hybrid mismatches”). Today’s (29 May) agreement completes the Anti Tax Avoidance Directive (ATAD) which ensures that binding and robust anti-abuse measures are applied throughout the Single Market. “Our campaign… – Continue reading
The U.K’s diverted profits tax was dubbed the ‘Google Tax’ even before its introduction in April 2015. Yet instead of netting foreign tech companies engaged in complex tax planning such as California-based Google Inc., only U.K. multinational companies outside the technology sector have issued warnings so far over the tax… – Continue reading
The United States continues to be a magnet for immigration, with nearly 8 million new immigrants settling here between 2008 to 2014 — and some of these new immigrants are high-net-worth individuals who are unprepared for the intricacies of the U.S. tax law, according to Seth Entin, a shareholder at… – Continue reading
