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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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…. – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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… – Continue reading
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,… – Continue reading
European Union finance ministers gave formal approval to legislation designed to dramatically reduce the 900-plus unresolved company cross-border double taxation disputes. The Oct. 10 approval for the EU Double Taxation Dispute Resolution Directivecomes amid skepticism from tax professionals that it has the resources to be effective. It includes mandatory binding… – Continue reading
The Irish government is inviting businesses and practitioners to provide feedback on its plans to update its international tax strategy, including how Ireland should incorporate the OECD’s transfer pricing guidelines into national law and implement the European Union’s anti-tax avoidance rules. The consultation, which runs until the end of January… – Continue reading
New Delhi [India], Oct.6 (ANI): In keeping with India’s commitment to implement recommendations of 2015 Final Report on Action 13, titled “Transfer Pricing Documentation and Country-by-Country Reporting”, the Department of Income Tax has invited comments from stakeholders and the general public. It has said that these comments and suggestions on… – Continue reading
International pension plans involve complex questions of structuring and compliance International Pension Plans (IPPs) are pension plans sponsored and funded by an employer, for employees assigned to work outside their home country, who are expected to receive IPP benefits while they are resident in their home country, or in another… – 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
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
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
