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PERTH (miningweekly.com) – US oil and gas major Chevron has withdrawn its High Court appeal over a A$340-million bill from the Australian Taxation Office (ATO).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 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
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
Four of the most significant transnational organizations are working together to eliminate transfer pricing schemes and abuses. The four organizations—the International Monetary Fund, the Organization for Economic Co-operation and Development, the United Nations and the World Bank Group—are seeking to achieve global cooperation in tax matters. Transfer pricing is one… – Continue reading
A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry… – Continue reading
New transfer pricing regulations issued by the State Administration of Taxation (SAT), the Measures for Administration of Special Tax Investigation Adjustment and Mutual Agreement Procedures (“the Measures”), came into effect on May 1, 2017. The Measures consolidate China’s pre-existing regulations regarding self-adjustment and outbound payments with the new transfer pricing… – Continue reading
East Africa tax experts have raised concerns over increasing cases of tax evasion and fraud by some tax payers in the region which is crippling the economies. They made the remarks on Wednesday during the 6th East Africa regional meeting on tax investigation and enforcement in the Rwandan Capital Kigali…. – Continue reading
The United Nations Committee of Experts on International Cooperation in Tax Matters has released, in digital format, the second edition of the UN Practical Manual on Transfer Pricing for Developing Countries. The 2017 edition of the TP Manual was launched at the UN Economic and Social Council Special Meeting on… – Continue reading
With a total of 15 action points, the OECD’s Base Erosion and Profit Shifting (BEPS) project aims at fighting the artificial shift of profits from jurisdictions with high taxes to tax havens, often as a part of an entirely legal strategy used by MNEs. The BEPS Action 13 (Transfer Pricing… – Continue reading
As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length… – Continue reading
China’s new transfer pricing rules, effective May 1, endorse the continued use of the arm’s-length standard—the internationally agreed bedrock for pricing transactions within multinational enterprises. The new guidance, Bulletin 6, augurs well for resolving tax disputes between China’s State Administration of Taxation and the U.S. Internal Revenue Service over the… – Continue reading
Move shows that Beijing is joining the global move against diversion of profits to low-tax jurisdictions Beijing on Saturday posted a new rule on scenarios that could trigger tax-avoidance investigations of multinationals, under¬lining its commitment to a global move to combat profit shifting. The new rule, posted on the website… – Continue reading
Multinational firms in South Korea tend to transfer much higher proportions of their revenues to their headquarters overseas in dividends and royalties than their Korean counterparts, an expert said Monday. Payments in royalties and dividends are categorized as expenses, which in turn lowers their reported earnings to the Korean authorities…. – Continue reading
The OECD effort to rebuild the global tax system should focus on practical work that benefits the international tax community rather than trying to get as many countries as possible around the table, a former Treasury official said. The OECD’s so-called inclusive framework for implementing the four minimum standards of… – Continue reading
Part 2: Transfer Pricing documentation requirements From 1 April 2017, BEPS action 13 guidelines on transfer pricing (TP) documentation will be effective in Sweden. Action 13 is an effort to make MNEs global financial situation more transparent. It is a three-tiered based approach including a master file, local files and… – Continue reading
Online giant wins transfer pricing case against US Internal Revenue Service Amazon. com has won a tax dispute with the US Internal Revenue Service (IRS), involving more than $1.5 billion (€1.39 billion), in relation to the transactions of a Luxembourg unit more than a decade ago. Judge Albert Lauber of… – Continue reading
MUMBAI: The recent changes in the India and South Korea Agreement for Avoidance of Double Taxation provides recourse to taxpayers of both countries to apply for Mutual Agreement Procedure (MAP) in respect of transfer pricing disputes, and also to apply for bilateral Advance Pricing Agreements (APA) for APA period beginning… – Continue reading
The Swiss government plans to bolster group financing activities by amending its withholding tax ordinance to exempt interest payments for certain intra-group loans. The goal of the amendment is to encourage Swiss-based multinational companies to pursue targeted financing activities in Switzerland rather than abroad, according to a March 10 news… – Continue reading
Tax reform is widely expected under the Trump administration by the corporate tax executives polled by BDO USA in a new survey. BDO’s 2017 Tax Outlook Survey polled 100 tax executives at public companies across the U.S., and found that 100 percent of the surveyed tax executives believe tax reform… – Continue reading
Luxembourg should seek to widen the tax base while ensuring that its corporate tax regime continues to meet international best standards, says the International Monetary Fund. It said that the country could improve its reputation by “promptly transposing” the EU’s Anti-Tax Avoidance Directive into national law and continuing to implement… – Continue reading
On October 1, 2016, the Indiana Office of Fiscal and Management Analysis of the Indiana Legislative Services Agency released a Combined-Reporting Study and a Transfer Pricing Study. These studies, which address corporate income tax issues, were required by legislation passed in 2016. The Combined-Reporting Study discusses the reduction of state… – Continue reading
South Korea’s tax authorities have been investigating the local importer of Toyota and luxury Lexus vehicles over suspected tax evasions since late 2016, industry sources said Friday. In November, the Seoul office of the National Tax Service (NTS) launched a tax audit into Toyota Korea over suspicions that it paid… – Continue reading
THE ORGANISATION for Economic Cooperation and Development (OECD) initiated the base erosion and profit shifting (BEPS) project in 2013 to address perceived gaps in international tax rules causing a loss of revenues for governments of about US$100 billion to $240 billion (Bt3.5 trillion to Bt8.4 trillion) annually. The OECD’s BEPS… – Continue reading
The Netherlands is slowly but surely steering away from facilitating the use of its corporate income tax system by companies that are set up merely to obtain tax benefits. These companies, which often do not actually carry out activities in the Netherlands, have contributed to the perception among policy makers… – Continue reading
