Global governments battling tax avoidance increasingly are pushing multinational corporations for a bigger picture of how and where they pay taxes, leading to increasingly narrow questions from company tax officers. “We have a number of entities that are disregarded for U.S. tax purposes. When I fill out the country-by-country form,… – Continue reading
Historically, the Middle East and North Africa (MENA) region has been perceived as a region where taxation and transfer pricing initiatives are not high up on government agendas. Although this has been the case for a significant period of time, recent changes in the region such as decreases in global… – Continue reading
The British arm of McDonald’s paid £123m for “franchise rights” last year, as part of a controversial structure that is under investigation for enabling unfair tax avoidance. The European Commission launched a probe last year into whether Luxembourg’s tax arrangements for McDonald’s amounted to illegal state aid, as part of… – Continue reading
The APA scheme was initiated in 2012 in the IT Act and in 2014, rollback provisions were introduced. The Dollar Business Bureau The Central Board of Direct Taxes (CBDT) on Thursday signed five Unilateral Advance Pricing Agreements (APAs) with Indian taxpayers, making the total number of APAs to 108. “The… – Continue reading
After five years of negotiations, the European Commission has finally announced its plans to overhaul the way in which companies are taxed in the Single Market. The revised Common Consolidated Corporate Tax Base (CCCTB) is aimed at making it easier and cheaper to do business in the Single Market and… – Continue reading
On October 26, Hong Kong’s Government launched a public consultation on the implementation of base erosion and profit shifting (BEPS) measures proposed by the OECD. “Hong Kong is supportive of international efforts to promote tax transparency and combat tax evasion,” said Secretary for Financial Services and the Treasury K C… – Continue reading
India has notified the revised double tax avoidance agreement with South Korea under which capital gains tax will be levied at the source with effect from April 1, 2017. The existing Double Taxation Avoidance Convention, which has been in vogue for three decades, provides for residence-based taxation of capital gains… – Continue reading
A new EU corporate tax proposal could fundamentally change how multinationals pay their tax bills in Ireland. It comes at a sensitive time for the State, following so closely after the commission ruled phone giant Apple tapped illegal tax breaks worth around €13bn. In proposals to be unveiled tomorrow, the… – Continue reading
China is requiring multinational groups to provide more information, including the location-specific advantages of their Chinese entities, when they apply for advance pricing agreements. The State Administration of Taxation’s Public Notice 64, dated Oct. 11 and released Oct. 18, requires companies to provide the additional information to Chinese tax authorities… – Continue reading
One of the most common ways multinationals take advantage of current laws to reduce their tax bill is through what’s known as transfer pricing. Former Treasurer Wayne Swan last week accused mining giant BHP of “aggressive transfer pricing,” denying the Australian government A$5.7 billion in tax revenue. For most companies,… – Continue reading
U.S. companies operating contract manufacturers in Mexico can avoid double taxation between the United States and Mexico under a deal struck between their respective tax authorities and unveiled Friday by the IRS. So-called maquiladoras can avoid double taxation through a unilateral advance pricing agreement signed with the Servicio de Administración… – Continue reading
Applicable to transfer pricing for MNCs whose consolidated annual revenue is over Rs 5,000 crore The finance ministry will issue rules and guidance to address some concerns and ambiguity over mandatory reporting norms with respect to transfer pricing for multinational companies whose consolidated annual revenue is over Rs 5,000 crore…. – Continue reading
Former Labor treasurer Wayne Swan has accused one of Australia’s biggest companies of evading taxes for more than a decade, and for lying to the former Labor government during the height of the mining tax debate. Swan used parliamentary privilege on Wednesday to claim BHP Billiton had been “gaming the… – Continue reading
The Inland Revenue Authority of Singapore (IRAS) has published detailed guidance on the implementation of a new country-by-country (CbC) reporting requirement in the territory. The guidance, released on October 10, sets out which entities are obliged to report and how to complete and submit a CbC report to IRAS. For… – Continue reading
EY announced today the results of a new tax survey at its 35th Annual International Tax Conference, “Unlocking the future.” The survey revealed that, more than ever, companies are experiencing an increasing number of audits and more aggressive enforcement from tax authorities around the world. According to the survey, nearly… – Continue reading
Various agencies are expected to work together to draft a decree and keep the practice in check. In a move that signals Vietnam’s apparent stronger stance against tax evasion, the Ministry of Finance has sought to work with other ministries and agencies to draft a new decree on transfer pricing… – Continue reading
Ethiopia recently adopted new transfer pricing rules in the form of Directive 43/2015 (“the Directive”) issued by the Ministry of Finance and Economic Development. The Directive provides detailed guidance as to the application of Article 29 of the Income Tax Proclamation (ITP) 286/2002, which requires taxpayers to ensure transactions between… – Continue reading
Ireland, accused of being a tax haven for multinationals such as Apple to pay nearly zero tax on the bulk of its profits earned outside the United States, finds itself with a new adversary in the global fight against unfair tax practices — Brazil. As of October 1, Brazil will… – Continue reading
A multi-billion euro back tax bill handed to Apple by the European Commission should not be seen as a precedent for future tax cases as it was based on state aid rather than tax law, the OECD official spearheading global tax reform said on Monday. European Union antitrust regulators last… – Continue reading
The threshold could be R5,400 crore of annual consolidated group revenue for the purpose of country-by-country reporting Not more than 120 India-headquartered firms — along with their global associates — are likely to be impacted by the base erosion and profit shifting (BEPS) protocol once it is implemented, as the… – Continue reading
India’s advance pricing agreements (APAs) programme crossed a milestone with the Central Board of Direct Taxes (CBDT) signing five more unilateral APAs. With the latest move, the total number of APAs entered into by the CBDT has reached 103. The five APAs signed on Friday pertained to diverse sector, that… – Continue reading
Auditing and tax advisory firm KPMG is calling for establishment of the T&T Revenue Authority (TTRA) so there can be a structured way of collecting taxes. “The current main tax authority does not appear to have structured means, if any, of treating with businesses that conceal transaction to avoid tax… – Continue reading
China’s State Administration of Taxation (SAT) issued the Announcement on the Administration of Related-party Transactions and Contemporaneous Documentation (SAT Announcement [2016] No. 42), which introduces a three-tiered documentation framework that will replace its current transfer pricing documentation rules. The June 29 announcement followed the publication of the opinion-seeking draft by… – Continue reading
Back in July, ABC’s The Business and Michael West featured an extraordinary raft of allegations from a 32-year veteran industry insider turned whistleblower, George Rozvany, who claimed that multinational tax avoidance was “out of control” and cost the Budget up to $50 billion dollars a year in lost revenue. Rozvany… – Continue reading
OECD Secretary General Angel Gurría has stressed the need for policy makers to provide a certain tax environment for businesses, to maintain trade and investment. Discussing the tax challenges facing EU countries at the informal meeting of EU finance ministers, held in Bratislava, Slovakia, on September 10, 2016, Gurría said:… – Continue reading
Apple Inc. may face double taxation on some of its profits if the European Commission’s Aug. 30 ruling inspires France to slap its own tax adjustment on the company, practitioners said. Apple could even face “triple taxation” if it repatriates profits from the European Union to the U.S., Laurent Leclercq,… – Continue reading
A recent 2016 tax reform in Japan (“Reform”) has introduced stringent Japanese Transfer Pricing Documentation Requirements, which require the preparation/filing of: (i) a Master File, (ii) a Country-by-Country Report, and (iii) a Local File, as well as (iv) a “Notification of the Ultimate Parent Entity.” Any ultimate parent company (“Parent… – Continue reading
The international tax landscape has been changing rapidly and the Organisation for Economic Co-operation and Development (OECD) has agreed on a base erosion and profit shifting (Beps) action plan that could affect businesses operating in the UAE. The plan addresses the issue of artificial shifting of profits and its proposals… – Continue reading
Today, we see more enthusiasm for tax reform in Indonesia. Although opposed by some civil society groups, President Joko “Jokowi” Widodo’s administration continues to push its fiscal framework reform — which includes a tax amnesty and more incentives for taxpayers. Last year, the Finance Ministry issued a new tax holiday… – Continue reading
The Central Board of Direct Taxes (CBDT) entered into twenty (20) Unilateral Advance Pricing Agreements (APAs) with Indian taxpayers. Many of these agreements also have a “Rollback” provision in them, Ministry of Finance said. The 20 APAs signed in these two days pertain to various sectors of the economy like… – Continue reading
Disclosures under the MAP are aimed at improving dispute resolution mechanism and are part of global initiative on base erosion and profit shifting. India will soon disclose the number of disputes being negotiated under the mutual agreement procedures (MAP) of tax treaties as well as details of the time being… – Continue reading
Under EU rules it is illegal for countries to give financial help to some companies and not others in a way that distorts fair competition, writes Liza Lovdahl Gormsen. State aid rules were originally designed to protect the internal EU market and avoid retaliation among member states. The US Treasury,… – Continue reading
The US has warned the EU that it risks damaging international agreements on tax reform if it continues to act as a “supra-national tax authority”. The US Treasury Department “shares the European Commission’s concern with tax avoidance by multinational firms. The international community, including the EU and its member states,… – Continue reading
THE OECD/G-20 Base Erosion and Profit Shifting (BEPS) Project is designed to provide solutions for governments to close the gaps in existing international rules that allow corporate profits to “disappear” or be artificially shifted to low or no tax environments, where companies have little or no economic activity. In February… – Continue reading
The U.K. government has been consulting on a proposed “Interest Restriction” rule which will limit the amount of interest expense U.K. companies will be allowed to offset against their income for tax purposes (to 30% of their taxable earnings before interest, tax and amortization). The second consultation phase on the… – Continue reading
An IRS official said the agency is continuing its work on a mechanism to allow voluntary filings of country-by-country reports for companies required to comply with both the U.S. rules and those in a foreign country with an earlier effective date. “Actually being able to accept CBC reports for the… – Continue reading
Apple is a major part of why the United States is the world’s leading innovator on new technologies, particularly those involving telecommunications and computers. The company has over 66,000 domestic employees, and a large percentage of its customers are here — at least 40 percent, according to its latest annual… – Continue reading
Companies doing business in Luxembourg will be required to file global tax information now that the nation has released draft legislation to implement new international tax reporting rules. The rules—known as country-by-country reporting—would require companies to submit a global blueprint outlining the location of their operations, taxes paid, income earned,… – Continue reading
The National Tax Service (NTS) Seoul Regional Office has been probing into a Korean processed food maker Paldo Company Ltd. since June on possible overseas tax evasion. According to the NTS Sunday, it has deployed international transaction investigators to investigate whether the instant food maker manipulated its transfer price to… – Continue reading
To provide certainty to taxpayers in the domain of transfer pricing by specifying the methods of pricing The Central Board of Direct Taxes (CBDT) has entered into an advance pricing agreement (APA) with an Indian subsidiary of a Japanese trading company to foster a non-adversarial tax regime. “Signing of this… – Continue reading
Transfer pricing documentation rules have come to the fore with the United Kingdom’s Brexit. The European Union and the Organization for Economic Cooperation and Development appear to apply similar transfer pricing documentation rules to multinational companies, but differences nevertheless abound. Some multinational enterprises may view these differences as nuances, but… – Continue reading
With elements of the Liberal government’s 2016-17 budget coming to fruition, tax lawyers must stay up to date with the changes as their workload increases, according to a global firm partner. Speaking with Lawyers Weekly, DLA Piper tax partner Jock McCormack (pictured) said tax lawyers can expect to be busy… – Continue reading
International tax experts are to convene in Canada on August 29-31, 2016, to discuss global transfer pricing developments and other issues affecting large corporations as a result of the OECD’s base erosion and profit shifting (BEPS) project. Bloomberg BNA and Baker and McKenzie will host two events: The 3rd Annual… – Continue reading
The world’s major economies need to deepen cooperation on tax collection as companies seek to minimise the amount they pay to governments, finance ministers said Saturday. The issue has become controversial in many countries, with multinational firms from Google to Starbucks facing accusations of not contributing appropriately to the economies… – Continue reading
During a recent speech in Pretoria to the High Level Conference on Illicit Financial Flows, South African Minister of Finance Pravin Gordhan noted that tax code improvements are required in African countries so that multinational enterprises (MNEs) “pay their fair share of taxes in the countries where they generate their… – Continue reading
Tax executives at U.S.-based multinational companies are having a hard time adjusting to the new rules demanded by the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting plan, also known as OECD BEPS, according to a new survey. While OECD BEPS is not a requirement in the… – Continue reading
The latest APAs signed with taxpayers pertain to various sectors like banking, information technology and automotives In a move designed to reduce tax litigation, the Central Board of Direct Taxes (CBDT) on Monday signed seven more unilateral Advance Pricing Agreements (APAs) with Indian taxpayers. “With today’s signing, the total number… – Continue reading
The German Federal Cabinet has adopted a bill to implement key aspects of the OECD’s base erosion and profit shifting (BEPS) recommendations and the European Union’s administrative cooperation directive. The Act Concerning the Implementation of Changes to the EU Administrative Cooperation Directive and of Additional Measures against Base Erosion and… – Continue reading
The OECD has released its standardised IT-format for the exchange on tax rulings (ETR) between jurisdictions to meet the new tax framework following adoption of BEPS Action 5 on countering harmful tax practices more effectively The ETR XML Schema is part of the OECD’s work to ensure the swift and… – Continue reading
The “Big Four” global accounting firms – PwC, Deloitte, KPMG and Ernst & Young – are the masterminds of multinational tax avoidance and the architects of tax schemes which cost governments and their taxpayers an estimated $US1 trillion a year, according to an Australian taxation expert. The controversial new claims… – Continue reading
