New Delhi/Mumbai: India’s goal of a friendlier tax regime for global companies to help power China-beating economic growth is hitting a manpower hurdle. Fewer than 20 officials face the complex task of working with hundreds of multinational companies (MNCs) on pacts to avert tax rows, people familiar with the matter… – Continue reading
Transfer pricing has been raking in significant tax controversies and has also emerged as one of the leading arms of the Indian tax law. Transfer pricing has been raking in significant tax controversies and has also emerged as one of the leading arms of the Indian tax law contributing a… – Continue reading
08/06/2015 – Pushing forward efforts to boost transparency in international tax matters, the OECD today released a package of measures for the implementation of a new Country-by-Country Reporting plan developed under the OECD/G20 BEPS Project. The Country-by-Country Reporting Implementation Package will facilitate a consistent and swift implementation of new transfer… – Continue reading
Chevron Australia boss Roy Krzywosinski was complaining two weeks ago that taxes were too high in Australia. It was a pretty suave call from Krzywosinski. The latest financial statements for Chevron Australia Holdings show the company not only managed to avoid paying tax last year but it even pulled off… – Continue reading
The resurgent interest in transfer pricing abuse by multinationals might be missing the first “link in the chain” – the shifting of profits inside South Africa to the detriment of empowerment partners, workers, communities and the economy. This is the emerging line from a prominent think-tank, the SA Mining Development… – Continue reading
Tax administrators would be allowed to use hindsight to evaluate the appropriateness of transfer-pricing decisions made by companies in transactions involving hard-to-value intangible assets under an approach proposed by the Organisation for Economic Co-operation and Development (OECD) on Thursday. The OECD’s discussion draft looks at the issue of arm’s-length pricing… – Continue reading
A paper production line of SAScoat Viet Nam. The company is suspected of engaging in transfer pricing. HA NOI (Biz Hub) — The Debt and Asset Trading Corporation (DATC) has asked the General Department of Taxation to investigate SAScoat Viet Nam for transfer pricing, online newspaper Investment said. The request… – Continue reading
June 5: The Organisation for Economic Co-operation and Development (OECD) yesterday released a discussion draft concerning work in relation to Action 8 under the base erosion and profit shifting (BEPS) project concerning hard-to-value intangibles. Read the BEPS Action 8 discussion draft [PDF 62 KB] The following discussion provides initial impressions… – Continue reading
IN the wake of budgetary constraints, the government of Tanzania is tightening transfer pricing regulations and bolstering its tax enforcement actions in order to create new revenues, and in doing so, has increased the administrative compliance cost and burden for companies. Indeed, the government’s apex body charged with the administration… – Continue reading
PLATINUM producer Lonmin came under renewed attack by Dick Forslund from the Alternative Information and Development Centre on Tuesday for its use of offshore entities to shift hundreds of millions of rand around the group. Using data presented at the Farlam commission of inquiry, Mr Forslund issued a report into… – Continue reading
The United States has the most damaging business tax system in the developed world because it taxes its businesses at high rates, taxes them on their worldwide income and denies them the ability to deduct the cost of their investments at the time they make them. There is wide agreement… – Continue reading
THE South African Revenue Service (SARS ) is to significantly beef up its capacity to deal with base erosion and profit shifting, which has received intense focus by MPs over the last few months. SARS commissioner Tom Moyane said on Wednesday 24 more tax specialists would be employed in the… – Continue reading
ANALYSIS Dakar, Senegal — Capital flight and illicit financial flows represent missed opportunities for generating state revenue desperately needed to finance key sectors of West Africa’s economy, tackle poverty and invest in social protection and safety nets. Though the exact amount lost annually is debated, the deficit is significant and… – Continue reading
Microsoft Corp. and the IRS are back in court, this time fighting about the U.S. tax agency’s interest in hiring David Boies, the lawyer who beat Microsoft in an antitrust case in 2000. The software company filed a federal lawsuit May 29 in Seattle, marking the latest legal flurry over… – Continue reading
The five biggest suppliers of publicly subsidised medicines in Australia recorded sales of nearly $5 billion last year but paid an average of just $10 million each in company tax. Research by the Parliamentary Library, obtained by Fairfax Media, has disclosed the tax contribution of multinational pharmaceutical companies, including Pfizer… – Continue reading
Africa is known as the ‘paradox of plenty’. How can a continent so rich in natural resources be so poor? Economic growth is predicted to increase by 4.5% across the continent this year, despite falling oil prices and the Ebola crisis. South Africa’s economy, the second biggest in Africa is… – Continue reading
New Zealand: Budget 2015 The New Zealand Budget was handed down on 21 May 2015 and included a new tax on residential property sold within two years of purchase (with some exceptions). For further information on the New Zealand Budget see PwC New Zealand’s Budget commentary. New Zealand: Issues paper… – Continue reading
With regard to direct tax, the government promulgated in 2012 a law named ‘Transfer Pricing’. The law is scheduled to be effective from July 01, 2015. Transfer pricing is a globally common phenomenon. In different countries of the world, this law is in existence. According to the best international practice,… – Continue reading
Half the 30 such cases, worth Rs 10,000 crore, to be addressed India is set to sign agreements with Japan to resolve as many as 15 transfer pricing disputes. These agreements follow the one recently signed with the US. The agreements will be for cases that fall in the ambit… – Continue reading
Brussels competition arm investigating Ireland for use of ‘comfort letters’ to companies The European Commission is to propose a mandatory common corporate tax base next month as part of a wide-ranging clampdown on corporate tax avoidance. Under a discussion document to be looked at by EU commissioners in Brussels today,… – Continue reading
The Swedish Tax Agency (STA) bears the burden of proof that pricing between associated companies differs from what would have been agreed between independent companies but this burden has proved difficult for it to meet. New approaches used by the STA in its investigations suggest it puts more effort in… – Continue reading
Muscat: Taxpayers across the globe, including Oman, are facing increased scrutiny of their tax returns and positions taken as the pressure on governments increases to raise revenues from taxes, says an expert at KPMG. Ashok Hariharan, partner and head of tax for KPMG in the Middle East and South Asia… – Continue reading
Investments Derived From Structural Reforms The approved structural Reforms are an unprecedented opportunity for a transformational economic growth in Mexico, being the most relevant from an investment point of view the reforms related to Energy, Telecommunications and Antitrust, which have put Mexico in the radar of Multinational companies seeking to… – Continue reading
The countries of the Central American region have incorporated and reformed their legislations to the international regulations of Transfer prices and practically all the applicable legal provisions to related parties have already been expanded in the region, which implies, that the companies with regional presence must visualize, review and engage… – Continue reading
K+, a television joint venture between Vietnam and France, well-known as the exclusive broadcaster of the British Premier League in Vietnam, has reported an accumulative loss of VND1.9 trillion after five years of operation. Since 2009, when it made its debut, K+, the television corporation to which the French Canal+… – Continue reading
Foreign-invested enterprises (FIEs) and foreign organizations last year topped all other economic sectors of Vietnam’s economy in social insurance debt with over VND2.13 trillion (US$97.9 million), according to a government report on the management and use of social insurance funds in 2014. This was a staggering 192.5 percent year-on-year surge,… – Continue reading
Businesses that operate globally continue to face complex tax issues, and transfer pricing – the practice of establishing arm’s-length prices for related-party cross-border transactions – has become more important than ever. When it comes to transfer pricing, I consider the Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational… – Continue reading
Litigation on transfer pricing issues has reached humongous proportion in India. The existing law of the use of arithmetic mean for determination of arm’s length price can be credited as a major igniter of such litigations as arithmetic mean had a tendency to be skewed by outlier comparables. Considering this… – Continue reading
Thailand’s capacity for tracking how multinational companies shift income across borders within the same group to understate tax payments will increase after a transfer pricing law comes into force. The transfer pricing law, which is being deliberated by the Council of State, will authorise Revenue Department officials to ask parent… – Continue reading
The government is crafting legislation to compel mining firms to release production data to the fiscus to help curb illicit financial flows (IFFs) and transfer pricing which is costing African countries at least $50 billion annually, finance minister Patrick Chinamasa said on Friday. IFFs have become a highly emotive issue… – Continue reading
NEW DELHI: The finance ministry on Thursday issued the draft scheme of proposed rules for computation of arm’s length price for international and specified domestic transactions between related entities undertaken on or after April 1, 2014. The use of multiple-year data and the “range” concept in the transfer pricing regime… – Continue reading
The Ukrainian legislation for transfer pricing came into force in 2013, with implementation of respective amendments to the Tax Code of Ukraine (“CCU”). However, at present the transfer pricing rules (provided for the CCU) are not applied accurately. In light of the above, in order to clarify the transfer pricing… – Continue reading
The Ukrainian legislation for transfer pricing came into force in 2013, with implementation of respective amendments to the Tax Code of Ukraine (“CCU”). However, at present the transfer pricing rules (provided for the CCU) are not applied accurately. In light of the above, in order to clarify the transfer pricing… – Continue reading
The UK’s introduction of the diverted profits tax (DPT) has dismayed tax practitioners and their multinational clients. Rushed through parliament (ahead of its dissolution before the general election) and in effect as of April 1, the DPT seemed intended to appease public anger at multinationals failing to pay their ”fair… – Continue reading
State agencies have had their reasons to keep the cases silent. However, this has angered the public and economists. Silence gives the public another reason to believe that many names on the black list of FIEs (foreign invested enterprises) conducting transfer pricing have not been exposed. Nguyen Duc Kien, deputy… – Continue reading
MUMBAI: The Central Board of Direct Taxes (CBDT) is taking a close look at 120 transfer pricing disputes with a view to settling them as the Narendra Modi government tries to rid India of the label that it’s overly aggressive on taxation. While the government aims to sign the 120… – Continue reading
1. Global focus on transfer pricing There has been a recent surge in regulatory attention around the world towards pricing arrangements within multinational corporate groups. Regulators are concerned that these pricing arrangements may be used as a means of profit shifting and therefore tax avoidance. The price at which an… – Continue reading
In 2014, the Organization for Economic Co-operation and Development (“OECD”) began making recommendations to Member States for the implementation of certain actions aimed at limiting base erosion and profit shifting, known as “BEPS”. The project includes 15 actions, representing 15 areas of regulation that allow states to monitor data which… – Continue reading
ALTHOUGH there is no conclusive evidence as to how much money South Africa is losing in terms of transfer pricing, the mining and extractive industries are responsible for R3.4bn of it. Dumisani Jantjies, financial analyst of the parliamentary budget office, singled out the mining industry as one of the biggest… – Continue reading
Addis Ababa, 19 May 2015- (ECA) – Africa’s money that could be used to improve lives and reduce poverty is leaving the continent through illicit financial flows defined as money illegally earned, transferred and used. As the Chairperson of the High Level Panel on Illicit Financial Flows from Africa, the… – Continue reading
Introduction Tax avoidance, however legitimate its mechanism, has become the new focus for public opprobrium in parts of the world. High-profile cases and media attention examining the tax strategies of major global companies operating primarily in the digital economy have all contributed to this shift of focus. How are the… – Continue reading
The Cabinet of Ministers of Ukraine has added Austria, Turkmenistan, Hong Kong and Niue to the list of countries transactions with which are subject to control under the administration of the law on transfer pricing. Corresponding Cabinet decree No. 449 dated May 14 has been posted on the website of… – Continue reading
Ruling opens door for HM Revenue & Customs (HMRC) to recoup losses from other firms which used rate-booster schemes High street retailer Next has been hit with a £22.4m tax bill after a court found that it diverted profits made in the UK to offshore havens to avoid paying tax…. – Continue reading
Authorities worldwide have increased scrutiny of tax-avoidance strategies in the past year, CFOs and finance directors of multinational clients told global tax consulting firm network Taxand. Sixty per cent of multinationals reported an increase in audits by tax authorities in the past year, and 70% said authorities had increased their… – Continue reading
OVER 50 judicial officers underwent a two-day training in emerging trends in tax law practice and administration organised by Uganda Revenue Authority (URA) to hone their skills in adjudication of revenue affairs. The training that closed last week was held at Lake Victoria Serena Resort, Kigo in Kampala. The training… – Continue reading
Marcelo Vicentini of Standard Chartered in Brazil discusses the differences between OECD member countries and non-members when it comes to asset management transfer pricing. Brazil’s diversion from the OECD is well-documented and can make life difficult for transfer pricing managers when they are trying to apply a consistent policy across… – Continue reading
SEOUL, March 17 (Yonhap) — The South Korean business community on Tuesday called for easing the tax audit burden and more deductions for corporate entertainment outlays to better reflect the rise in overall expenses. In a meeting with National Tax Service Commissioner Lim Hwan-soo in Seoul, companies belonging to the… – Continue reading
KUALA LUMPUR: MIDF Equities Research says the Malaysian stock market is in need of a spark after its rather indifferent response to the strengthening of the ringgit and the oil price. The research house said the Bursa Malaysia’s indices have traded in a narrow range in the last three weeks…. – Continue reading
SEOUL, March 17 (Yonhap) — The South Korean business community on Tuesday called for easing the tax audit burden and more deductions for corporate entertainment outlays to better reflect the rise in overall expenses. In a meeting with National Tax Service Commissioner Lim Hwan-soo in Seoul, companies belonging to the… – Continue reading
The I-T dept has received over 500 applications from MNCs for signing APAs. Income-tax department has set a target of 50 advance pricing agreements (APAs) to be sealed with multinational companies in the current fiscal that will exempt cross-border transactions by these firms from rigorous auditing to check income suppression…. – Continue reading
