Since 2002, there has been a steep escalation in transfer pricing disputes in the country, the ‘Taxsutra’s TP Trends Report’, is a perfect compendium which encompasses this escalation. The Chapter under which Transfer Pricing provisions were introduced was with the intent to ensure that there is no avoidance of tax…. – Continue reading
The rogue regime in Banjul is on the verge of finalizing an Offshore Banking deal with some Hong Kong multi-million dollar companies, the Freedom Newspaper can reveal. Under the new deal, the Jammeh government is going to open an Offshore Bank in The Gambia, with the primary objective of helping… – Continue reading
The new Indian Government, led by Prime Minister Mr. Narendra Modi, assumed office in May 2014 with the election promise to deliver on reviving economic growth, investor confidence and bringing consumer demand back on track. The key stated goal is to move away from a control-and-command economy towards a market… – Continue reading
RBI governor Raghuram Rajan has called for a transparent and predictable tax regime. His words are well-timed, coming as they do just before the Budget exercise starts. Investors want certainty and stability in the tax system. Recently, the government dropped all past demands of minimum alternate tax on foreign portfolio… – Continue reading
Carl Icahn, the iconic activist investor, has shifted, if only for today, his cross-hairs of contempt from the boardrooms of corporate America to the nation’s capital. Icahn sends members of Congress a word of warning Wednesday saw Carl Icahn warn several members of Congress a letter laying out his plans… – Continue reading
NEW DELHI: The government has issued the final rules to incorporate range concept and use of multi-year data in transfer pricing calculations to reduce litigation and bring Indian laws in line with international practices. The Income Tax Department had issued the draft of the rules in May inviting stakeholder comments…. – Continue reading
A recent Thomson Reuters survey report reveals that European companies are outpacing all others in developing their Base Erosion and Profit Shifting (BEPS) action plans by Dec. 31, 2017 – the deadline set by the Organization for Economic Cooperation and Development (OECD). But most respondents voiced several concerns about BEPS… – Continue reading
CHINA may implement new rules by the end of this year to prevent tax evasion by multinational companies as the G20 has endorsed a plan to enhance fairness of international tax revenue, Ernst & Young said. The State Administration of Taxation last Friday finished collecting feedback for amendments to a… – Continue reading
On October 5, 2015, the Organization for Economic Cooperation and Development (“OECD”) released its final report on the 15 key elements of international tax rules set out in its Base Erosion and Profit Shifting (“BEPS”) Action Plan. The OECD launched the BEPS Action Plan in 2013 at the request of… – Continue reading
On 17 September, 2015, China State Administration of Taxation (“SAT”) released the Discussion Draft for the Implementation Measures for Special Tax Adjustments (“Discussion Draft”) to overhaul the existing trial version of the Implementation Measures, i.e., Circular 2. In the chapter of “Contemporaneous Documentation” of Discussion Draft, SAT introduces an entirely… – Continue reading
WHEN public spending is being slashed in a way that punishes the poor, every firm have a moral obligation to pay their fair share. AMAZON are taking an ever bigger share of the shopping market. Technological advances mean you can order something from their website late at night from your… – Continue reading
On Oct. 5, 2015, the Organization for Economic Cooperation and Development (OECD) released a set of final reports on its 15 point action plan to address Base Erosion and Profit Shifting (BEPS). In an accompanying explanatory statement, the OECD also included plans for additional work on technical matters and a… – Continue reading
Beijing’s monetary easing has sent onshore yields to multiyear lows, reports the Wall Street Journal. China’s booming domestic debt market is pushing investors to seek higher yields offshore, just as its banks start to expand yuan lending world-wide. The shift comes as China’s central bank is selling its first yuan… – Continue reading
Some might be surprised to learn that certain areas of Richmond and Vancouver, despite being thoroughly decorated with mcmansions, monster homes, and incessantly rising land prices, are actually inhabited by low income residents that make up a surprising per cent of the population. Conservative Party leader Stephen Harper, during a… – Continue reading
Offshore companies are established for a variety of reasons including a company’s necessity to restructure, create an international business entity as well as protect the assets of the company. The United Arab Emirates (UAE) is home to three authorities that register International or offshore companies. The three UAE authorities that… – Continue reading
Three years ago, Chinese officials said U.K. Prime Minister David Cameron had “seriously damaged” relations by meeting with the Dalai Lama, the exiled Tibetan leader. As planned talks between the two countries were canceled or failed to take place, worries emerged that Britain would miss out on building deeper economic… – Continue reading
NUMBER OF THE WEEK: 0 The number of House Republicans who want to be speaker and can actually secure the necessary 218 votes as of today. After Majority Leader Kevin McCarthy’s dramatic exit from the race last week, the House GOP conference is taking the week-long Columbus Day recess to… – Continue reading
Govt is also in the process of formulating guidance with respect to specified domestic transactions within the group In a bid to promote business-friendly taxation regime, the Centre has issued guidelines for transfer pricing (TP) provisions that are expected to reduce the rising volume of tax litigation. According to the… – Continue reading
MUMBAI: There is a sudden, inexplicable surge in money that Indians are sending abroad for ” maintenance of close relatives“. Such fund transfers typically add up to $10-20 million a month. But in July 2015, according to the latest available data, total remittance under this head crossed $124 million. Also,… – Continue reading
UBS trades at 1.7 times book value while Barclays and Deutsche Bank trade at 0.7-0.8 times book value UBS RoE is 14 per cent while Barclays and Deutsche Bank can hardly manage five per cent. Ubs under Marcel Ospel was a victim of the 2008-09 global crash that lost $50… – Continue reading
KOLKATA (miningweekly.com) – The Indian federal government has zeroed in on the mining sector as the prime repository of “black money” and unaccounted wealth stashed overseas, and was instructing a clampdown by tax authorities. In a directive to tax authorities, including the Income Tax Department (ITD), the Finance Ministry observed… – Continue reading
Background The transfer pricing debate between the taxpayers and the Indian tax authorities has been a never-ending story. The taxpayers in India have faced eleven rounds of transfer pricing audits so far. Each round of transfer pricing audit has seen new controversies in areas such as marketing intangibles, share valuation,… – Continue reading
The British Virgin Islands (BVI) said it is already committed to publishing an anti-money laundering action plan after another worrying report emerged; this time listing the territory among the top 10 countries to which identified United Kingdom criminal assets have been laundered. The BVI is actually the only Caribbean country… – Continue reading
The Turnbull government has welcomed the support of the Labor party for the new laws that will add more teeth to the government’s crackdown on multinational tax dodgers. The government also offered to consider the suggestions of the opposition in improving the scope of the legislation. Labor formally announced its… – Continue reading
THE CABINET has approved the Finance Ministry’s proposal for more tax incentives to facilitate the creation of International Headquarters and International Trading Centres in Thailand. IHQs and ITCs in the Kingdom currently enjoy both tax and non-tax benefits, including complete income-tax exemption for out-out transactions, while in-out transactions will be… – Continue reading
NEW DELHI: Foreign portfolio investors have sought stability in taxation policies as the government looks to lure them to set up fund management business in the country. They have made a number of suggestions, Economic Affairs Secretary Shaktikanta Das said after a meeting of the finance ministry with representatives of… – Continue reading
South Korea is seeking ways to levy a corporate tax on profits of global technology companies and other multinationals as early as next year in response to growing criticism of their tax avoidance structures. The diverted profits tax is more widely called the “Google tax,” as U.S. tech giants such… – Continue reading
[HONG KONG] China’s central bank has hired banks to arrange its debut offshore yuan bond issuance in London, according to a term sheet seen by Reuters on Monday. The so-called dim sum bond sale comes as Chinese President Xi Jinping prepares for a state visit to Britain this week. Sources… – Continue reading
On 17 September, 2015, China State Administration of Taxation (SAT) released the Discussion Draft for the Implementation Measures for Special Tax Adjustments (“Discussion Draft”), as a complete revamp to the existing trial version of the Implementation Measures, i.e., Circular 2. Circular 2 has been serving as a backbone transfer pricing… – Continue reading
Shadow Assistant Treasurer Andrew Leigh will tell parliament on Monday that his party plans to support the coalition’s multinational tax avoidance crackdown. The federal government has welcomed support from the opposition for its planned crackdown on multinational tax dodgers. Extending the olive branch, the federal government is also prepared to… – Continue reading
The Base Erosion and Profit Shifting (BEPS) project, a joint initiative between G20 countries and the OECD, works towards the development of a coherent global taxation system which addresses BEPS concerns. The main purpose of such initiative is to address the gaps in the current international tax rules relating to… – Continue reading
Legislative Activity House Lawmakers Schedule Markup of Transportation Bill Without Revenue Provisions Last week, on Friday, October 16, the House Transportation and Infrastructure Committee released a six-year, $325 billion highway funding bill (the Surface Transportation Reauthorization and Reform Act of 2015); a markup of the legislation is scheduled for Thursday,… – Continue reading
Introduction On 5 October 2015, the OECD delivered the final package (“Final Package”) of its comprehensive Action Plan on Base Erosion and Profit Shifting (“BEPS“). This marks a culmination of a process that started in September 2013, when the Group of 20 (“G20”) Leaders first endorsed the Action Plan on… – Continue reading
Kolkata Bench of Tribunal in the case of Outotec GmbH v. DDIT : ITA No. 431 & 432 of 2014 & 283 of 2015 (Kol) dealt with the issue as to whether the sale of equipment, designs and drawings would be taxable under the provisions of the India-Germany DTAA and… – Continue reading
(Bloomberg) — China Construction Bank Corp. became the first Chinese bank to receive permission to offer commercial- banking services and clear renminbi transactions in Switzerland. The Swiss financial regulator, Finma, granted the bank permission to open a branch in Zurich, a spokesman said by phone Monday. China Construction Bank applied… – Continue reading
EY: Four out of 10 Czech businessmen asked for bribe Four out of 10 Czech entrepreneurs have been explicitly asked for a bribe and up to six out of 10 have encountered the possibility of gaining an advantage in their business in exchange for a bribe, according to a survey… – Continue reading
TEMPO.CO, Jakarta – The Perkumpulan Prakarsa (Center for Welfare Studies) executive director Setyo Budiantoro viewed that the government must revise the banking secrecy provisions in the Law on Banking to reduce illicit outflows from Indonesia. According to Budi, Indonesia applies regulations that require citizens to report their wealth in all… – Continue reading
A little over a week ago the British parliamentarian, Sir Eric Pickles – a cabinet member until May of this year and a former Chairman of the Conservative Party – told the London Guardian that the British Prime Minister, David Cameron, was determined to have the BVI and the Cayman… – Continue reading
The rising wealth of Asia Pacific nations, including Singapore, means more and more people have looked internationally for opportunities to invest in overseas property markets. Recent stock market events have shown the importance of a diversified portfolio capable of riding out the storm when economic conditions put immense pressure on… – Continue reading
The federal government will be seeking the opposition’s support for new laws that crack down on tax-dodging multinationals but Labor looks to be on its own pursuing Malcolm Turnbull over his offshore investments. There are hopes that the four-day sitting of the lower house starting on Monday will also bring… – Continue reading
Concerned about the impact of tax havens, world powers are tightening the noose on multinationals seeking tax advantages. India wants changes to its tax treaty with Mauritius, forcing the island’s new government to re-examine its business model and focus elsewhere. There is debate in the new government, which took office… – Continue reading
NEW DELHI: Looking to streamline the taxation procedure, CBDT has issued detailed guidelines on transfer pricing cases that are expected to bring about uniformity in determining arm’s length price in similar instances. As per the regulations, each Transfer Pricing Officer (TPO) will be assigned a given number of important and… – Continue reading
HONG KONG: Pakistan and Hong Kong SAR signed a landmark agreement for the avoidance of double taxation and prevention of fiscal evasion with respect to taxes on income on Friday, a statement said. The agreement once implemented by Pakistan and Hong Kong SAR would encourage investment and business between the… – Continue reading
A new Protocol to the income tax treaty between Indonesia and the Netherlands was signed 30 July 2015 and will be effective 31 days after formal approval and ratification by both governments. Among the measures contained in the Protocol are revisions to the withholding tax rates on dividend payments. The… – Continue reading
Several close associates of Russian President Vladimir Putin may have benefited from Deutsche Bank AG trades that are now coming under the glare of U.S. prosecutors, according to people familiar with the matter. The U.S. Department of Justice is investigating whether Germany’s biggest bank properly vetted as much as $6… – Continue reading
The central government is stepping up its anti-graft drive by cracking down on illegal lending and money-laundering operations in a bid to prevent outbound flows of stolen assets. The Ministry of Public Security says “black banks” and illegal currency exchanges have facilitated the flights of a number of former government… – Continue reading
BENGALURU: The Karnataka tax department’s recent proposal to e-commerce firms, considered a face-saver, may not be legally tenable, tax experts said citing High Court and apex court rulings. The Karnataka commercial taxes department, last week, asked e-commerce firms including Amazon, Flipkart and Snapdeal to deduct 1% of the money payable… – Continue reading
The following editorial appears in Friday’s Yomiuri Shimbun: International cooperation must be bolstered to close tax loopholes that can be exploited by multinational business corporations. The Group of 20 major economies and the Organization for Economic Cooperation and Development have worked out new international taxation rules to clamp down on… – Continue reading
Hong Kong (HKSAR) – The Hong Kong Special Administrative Region Government noted that the European Commission (EC) updated its webpage on October 12 on the listing of non-cooperative tax jurisdictions amongst the European Union (EU) Member States. After the Government’s liaison and clarification with relevant authorities, the technical error of… – Continue reading
(Bloomberg) — The People’s Bank of China is considering starting direct trading between the yuan and the Swiss franc, according to three people with direct knowledge of the matter. The Swiss franc would become the seventh major currency to be exchangeable directly for yuan in Shanghai, joining the U.S., Australian… – Continue reading
