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...
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...
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...
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...
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...
The OECD has published new transfer pricing country profiles for Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay, bringing the number of such overviews published by the OECD to 44. The profiles explain the current transfer pricing legislation and practices of each country....
The Central Board of Direct Taxes ( CBDT ) has released Central Action Plan for the First Quarter April 2018 to June 2018 of the FY 2018-2019. The Key Result Areas of the Action Plan and the Time Frame in the which it is to be achieved has been categorically...
The Centre for Trade Policy and Development (CTPD) has commended the Zambia Revenue Authority (ZRA) for exposing the tax evasion scam worth K76.5 billion in the extractive sector. The center has also welcomed intentions by the authority to undertake an extensive audit of mining companies. CTPD Executive Director Isaac Mwaipopo...
Jakarta. Indonesia’s tax office plans to spend hundreds of millions of dollars to update its outdated technology to boost low tax compliance and raise revenue collection in Southeast Asia’s largest economy, the country’s tax chief told Reuters. Indonesia completed one of the world’s most successful tax amnesties in 2017, but...
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...
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...
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...
The introduction of a unilateral revenue tax on digital businesses in the UK would stymie investment and be a strangely timed gamble, says accountancy firm Moore Stephens. The Government’s position paper, “Corporate tax and the digital economy,” released at the recent Spring Statement, includes a proposal to tax certain tech...
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,...
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...
On December 29, 2017, Hong Kong gazetted the Inland Revenue (Amendment) (No. 6) Bill 2017 (the Amendment Bill). The Amendment Bill, which was formally introduced into the Legislative Council on January 10, represents a crucial step in the development of Hong Kong’s transfer pricing regulatory and enforcement regime. The objectives...
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...
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...
The Inland Revenue Authority of Singapore (IRAS) on February 23, 2018, released the fifth edition of its Transfer Pricing Guidelines for income tax. During a public consultation held in June 2017, stakeholders asked the Ministry of Finance to provide more clarity and guidance on transfer pricing documentation (TPD) requirements, specifically...
The problems posed by the digitalization of the economy should be addressed collectively and any interim measures taken by countries unilaterally should be “as little damaging as possible,” the OECD’s Director of Taxation has said. Pascal Saint-Amans told the Irish Independent that to “find a long-term solution, you need to...
HÀ NỘI– Foreign direct investment (FDI) enterprises, which have enjoyed multiple tax incentives, pay the lowest State taxes despite reporting high profits, statistics show. FDI enterprises have achieved the highest profit growth among the economic sectors, generating VNĐ327.4 trillion (US$14.4 billion) in pre-tax profits in 2016, an increase of 17.3...
KUALA LUMPUR: The Inland Revenue Board (IRB) will raise the level of awareness among taxpayers and boost compliance rate among them to achieve a collection target of RM134.7 billion this year. It chief executive officer (CEO) Datuk Seri Sabin Samitah said that in 2017, tax collection rose by 8.15% compared...
The Bermuda Government on January 31, 2018, updated the lists of the countries with which it will exchange country-by-country reports filed in Bermuda in 2018 and in 2019. The Government has disclosed that it expects to exchange CbC reports with a total of 41 territories in 2018 relating to financial...
Ukraine’s Law No. 2245-VIII “On Introduction of Changes to the Tax Code of Ukraine and Some Legislative Acts of Ukraine on Ensuring the Balance of Budget Revenues in 2018,” which came into effect on January 1, 2018, includes important changes to transfer pricing (TP) regulations. These changes are outlined below....
Washington–Ahead of Finance Minister Arun Jaitley’s last full Union Budget, the US-India Business Council (USIBC) has urged him to further reduce tax uncertainty for multinational companies and foreign investors, even as Indian industry has voiced its own areas of concern. In a memorandum submitted to Jaitley, the USIBC has said...
On December 29, 2017, the Inland Revenue (Amendment) (No. 6) Bill 2017 (BEPS bill) was gazetted in Hong Kong. The BEPS bill introduces a transfer pricing regulatory regime and mandatory transfer pricing documentation requirement in Hong Kong as well as a variety of other anti-BEPS changes. The BEPS bill marks...
Viet Nam News HA NOI — In the latest draft of Law on Corporate Income Tax (CIT), the Ministry of Finance has raised a regulation aimed at preventing multinational companies with related-party transactions from evading taxes. According to the proposed regulation in the amended draft, the part of interest expense...
Apple Europe Ltd, a wholly owned subsidiary of Apple Inc., said it expects to pay more tax in the UK and paid an extra GBP136m for prior years up to September 26, 2015, after an extensive audit by HM Revenue and Customs. In its end-of-year accounts made up to April...
The Income Tax Department recently released a clarification stating that it would accept requests for mutual agreement procedures (MAPs) and bilateral advance pricing agreements (BAPAs) in transfer pricing disputes with all countries regardless of the existence of specific provisions in the Double Taxation Avoidance Agreements (DTAAs). A 2012 survey by...
THE Cabinet yesterday approved a draft bill aimed at preventing the transfer of assets and profits for the purpose of avoiding tax liabilities. Also approved yesterday were proposals requiring that juristic persons with interconnected transactions of more than Bt30 million a year send the authorities a clarification report and a...
India entered into three more advance pricing agreements in December, with two unilateral agreements and a bilateral APA concluded with authorities in the United Kingdom. With the signing of these agreements, the total number of APAs entered into by the Central Board of Direct Taxes totals 189, comprising 173 unilateral...
A number of trends are converging, and U.S. tax reform will make navigating them more complex. Those handling international M&A tax planning are facing two sets of challenges that require more proactive tax planning across the board. The first is the tightening fiscal net around the structure and financing of...
The FINANCIAL — Transfer Pricing Rules were implemented by the Government of Georgia in 2011, based on OECD guidelines. Since the number of international companies in Georgia is increasing steadily, Transfer Pricing Rules have become a point of obvious interest. However, multinational companies operating in Georgia are not sufficiently well-informed...
The International Centre for Tax and Development has released a working paper on how to best support developing countries in the area of taxation. The paper says that developing countries would particularly benefit from support in the implementation of two areas that were covered by the OECD’s base erosion and...
The Serbian Ministry of Finance has published draft amendments to the Corporate Income Tax Act (CITA), which are expected to be formally approved by the Government within days. If approved by the Parliament, as expected, CITA amendments will take effect from 1 January 2018. The most important novelties concerns recognition...
Bermuda and the UK recently signed an agreement providing for the automatic exchange of country-by-country reports. Bermuda is the first UK Overseas Territory to sign a CbC Competent Authority Agreement with the UK, which enables the automatic reporting of corporate income on a country-by-country basis for UK-related transfer pricing enforcement...
NEW DELHI The Indian Income Tax Department will accept applications for Mutual Agreement Procedure (MAP) in transfer pricing disputes, as well as for bilateral Advance Pricing Agreements (APAs), even for entities resident in countries with which India has double taxation avoidance agreements (DTAA), minus the provision to claim corresponding tax...
The Australian Taxation Office (ATO) has extended until February 15, 2018, the deadline for “significant global entities” to file their country-by-country (CbC) reports. The extension applies to entities that are December and January balancers filing for the first time. The extension also applies to the filing of local and master...
Africa is estimated to have lost over $1 trillion in illicit financial flows (IFFs) within the past 50 years, with drainage of over $50 billion annually. These outflows, according to the African Union and Economic Commission for Africa (AU/ECA) High Level Panel on Illicit Financial Flows (IFFs), refer to “money...
Bulgaria has said that multinationals covered by the country’s new transfer pricing country-by-country reporting regime should submit their first report by December 31, 2017. Through Order 3LIY-1410, Bulgaria’s National Revenue Agency has newly set out the rules concerning country-by-country documentation, including who the reporting obligations apply to and how to...
Ghana is considering promulgating laws to criminalize the abuse of transfer pricing in its petroleum sector, the Acting Chief Executive Officer of the Petroleum Commission, Mr. Egbert Faible, has disclosed. According to Mr. Faible, the abuse of transfer pricing in the country’s budding petroleum sector was worrying and there was...
CBDT issues final rules for Master File and Country-by-Country reporting NEW DELHI, NOV 1: The Central Board of Direct Taxes (CBDT) has notified the final rules for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country (CbyC) report. This is largely in line with the draft...
Lawmakers warn against preferential treatment for foreign invested companies, half of which declared losses from 2007-2015. Vietnam offers many land and tax incentives to attract foreign direct investment (FDI), but the sector’s contribution to the economy is still limited, said delegates of the legislative National Assembly (NA). Despite accounting for...
The OECD’s Anti Base Erosion and Profit Shifting Initiative (BEPS) significantly affects current transfer pricing regimes regarding intangibles, documentation and dispute resolution. Why is Transfer Pricing relevant for BEPS? To avoid base erosion and profit shifting of multinational companies, the OECD initiated an action plan consisting of 15 actions with...
The Japanese National Tax Agency (NTA) has released guidance for taxpayers on the mutual agreement procedure (MAP), in line with the recommendations of the OECD’s Base erosion and profit shifting (BEPS) Action 14 Final Report. The guidance is intended to supplement the Commissioner’s Directive on the Mutual Agreement Procedures, which...
In a dramatic turn of events in the Ghana Revenue Authority (GRA) and Vodafone Ghana tax dispute before court, the Acting Commissioner-General of the GRA has refused to grant a waiver of the payment of 30 per cent of the value of tax in contention. In a letter to Vodafone...
Thirty-eight African tax authorities recently converged in Abuja for the International Conference on Tax in Africa. The group discussed ways to boost revenues in Africa, in particular and how to improve collection of corporate income tax, reports Nduka Chiejina (Assistant Editor) Tax collection has never been a piece of cake...
Imagine a world where Indian tax authorities can look at a document to see whether a multinational company is paying taxes commensurate to the profit it generates in India. The genesis of such a world lies in OECD’s Base Erosion and Profit Shifting Project. Back in 2015, the Organisation for...
Singaporean lawmakers approved the Income Tax (Amendment) Bill 2017 on October 2, 2017, which provides for numerous changes to income tax policy. Discussing the bill in parliament, Indranee Rajah, Senior Minister of State for Finance, confirmed that the existing corporate income tax rebate for 2017 will be enhanced by raising...
An estimated $3.5 billion in revenue from large corporates and multinationals is at risk to the economy, but through audit activity this will reduce to $2.5 billion, according to the Australian Taxation Office. On Wednesday the agency is releasing the first tranche of its long-awaited highly anticipated “tax gap” figures,...
