Category: G20

Ireland: Aviation Finance & Leasing 2022

Financing structures involving Irish entities often employ the use of a special-purpose vehicle ("SPV"), which is a company established specifically to hold title to the aircraft subject to the financing and to lease those aircraft to the operators. Ireland is a popular jurisdiction for the establishment of SPVs due to the numerous double-tax treaties in place between Ireland and other countries, many of which specifically refer to aviation in their text. Ireland is also attractive due to the confidence in the legal and court system (which is broadly based on English common law) and the number of aviation experts and leasing companies based in Ireland. ... - Continue reading

What is the global minimum corporate tax?

The global minimum corporate tax on MNCs was aimed at discouraging them from shifting profits to low-tax countries. But it will reduce the incentives to attract investment in developing countries ... - Continue reading

Cyprus: European Mandatory Disclosure Regime (EU MDR) – A New Reality For Cypriot Intermediaries, Another Burden On Cypriot Taxpayers?

Mandatory disclosure rules are not something new for European Member States ("EU MS"). In fact, with the United Kingdom leading the race (from 2004), Ireland (in 2008) and then Portugal (in 2011) were the first -and only- EU MS to introduce mandatory disclosure rules in their local legislation. ... - Continue reading

Roundup: G20 financial meeting focuses on coronavirus, taxation, global economy

The finance ministers and central bankers of the Group of 20 (G20) discussed issues of the coronavirus, taxation and global economy during a two-day meeting concluded on Sunday in Riyadh. The G20 financial officials agreed to observe the risks of the coronavirus outbreak and adopt policies to limit its global… – Continue reading

Countries launch review of country-by-country reporting framework for multinational groups

An OECD-led group of 137 countries that work together on multinational group tax issues has released a consultation document and has requested public feedback to assist in a planned review of country-by-country reporting. The countries, known as the “Inclusive Framework on BEPS,” also scheduled a public consultation on the topic for March 17.
... - Continue reading

Switzerland: Italian Tax Authorities Request Information From Switzerland On UBS Bank Customers

In the past ten years, Switzerland has undertaken significant efforts to combat international tax fraud and tax evasion and to fight for the strict observance of foreign tax laws. In order to do so, a number of tax laws were enacted, allowing Switzerland to comply with international standards issued by the OECD (acting on behalf of the G20). In this respect, Switzerland ratified the Multilateral Convention on Administrative Assistance originally issued by the CoE and the OECD in 1988 and amended in 2011 ("OECD MC"), and it renegotiated numerous Double Taxation Conventions ("DTC"), amongst them also the DTC with Italy, in order to comply with the international standard introduced by the OECD MC in the version of July 2010. ... - Continue reading

Canada: Canada Ratifies The Multilateral Instrument

On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance.   ... - Continue reading

Worldwide: OECD Public Consultation Document And Public Commentary On The Tax Challenges Of Digitalisation

In February and March of 2019, the OECD organized a public consultation process, releasing a consultation document on February 13, 2019, inviting public comments up until March 6, 2019, and holding a conference where industry experts presented key issues on March 13 and 14, 2019. ... - Continue reading

The latest APA and MAP figures in Europe: what are the implications for multinational group taxpayers?

Statistics published earlier this week by the European Commission on member state advance pricing agreement (APA) and mutual agreement procedure (MAP) programs suggest that the OECD/G20 base erosion profit shifting (BEPS) project has increased the scope for differences of opinion between tax authorities of different countries. ... - Continue reading

OECD Finds Tax Automatic Exchange has Increased Transparency, Agrees on Digital Economy Taxation Roadmap

6 July 2019: In the lead up to the Group of 20 (G20) Finance Ministers and Central Bank Governors’ Meeting, the Organisation for Economic Co-operation and Development (OECD) released data that show that automatic exchange of information on financial accounts is improving tax compliance and delivering concrete results for governments… – Continue reading

Wolfsberg Group Publishes Guidance on Customer Tax Evasion

Financial institutions should be able to leverage existing financial crime compliance, conduct and tax (including tax transparency regimes) procedures and controls, to address the risks of customer tax evasion. The Wolfsberg Group has published new guidance on customer tax evasion, designed to help financial institutions in developing, implementing and maintaining… – Continue reading

OECD moves toward consensus on taxing multinational tech companies

The Organization for Economic Cooperation and Development is making progress on dealing with the tax challenges of the digital economy with a goal of arriving at a new consensus-based long-term solution in 2020. The OECD announced last week that the countries and jurisdictions participating in the OECD/G20 Inclusive Framework on… – Continue reading

Australia targets offshore banking units

Under pressure from international organisations, the Australian government has flagged that it is getting ready to reform the concessionally-taxed offshore banking unit (OBU) regime, a move that will hit big banks and hedge funds. The Organisation for Economic Co-operation and Development’s (OECD) forum on harmful tax practices has raised concerns… – Continue reading

China Joins International Financial Data Exchange to Take on Tax Evasion

(Yicai Global) Sept. 5 — China’s tax authority will begin sharing residents’ financial investment data with around 100 countries this month in a bid to crack down on tax evasion. The State Administration of Taxation will begin exchanging data to learn more about what Chinese citizens are doing with their… – Continue reading

BEPS Project Has Triggered Near-Global Tax Reform: OECD

The OECD has committed to providing proposals to fix the taxation of the digital economy by 2020, in an update to G20 leaders on international efforts to mitigate base erosion and profit shifting (BEPS). In the newly released Second Annual Progress Report of the OECD/G20 Inclusive Framework on BEPS, the… – Continue reading

European Leaders Press for New Digital Tax at G20 Meeting

European finance officials just wrapped up a G20 summit in Argentina where they pressed for new global rules to better collect tax on digital giants like Google (NASDAQ:GOOGL 1258.15 0.04%), Facebook (NASDAQ:FB 214.67 0.02%), and Amazon (NASDAQ:AMZN 1829.24 0.02%), among others. The European Commision is the executive (read: tasked with… – Continue reading

Peru Ratified OECD’s Multilateral Tax Convention

Peru has completed the necessary steps to become a party to the OECD Multilateral Convention on Mutual Assistance in Tax Matters and also the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions. On May 28, 2018, Peru’s Minister of Economy and Finance, David Tuesta, deposited… – Continue reading

BEPS Multilateral Instrument To Enter Into Force

The OECD has announced that its multilateral convention to implement tax treaty-related measures to counter base erosion and profit shifting will enter into force on July 1, 2018. The Convention, negotiated by more than 100 countries and jurisdictions under a mandate from G20 Finance Ministers and Central Bank Governors, will… – Continue reading

OECD Releases First Peer Reviews On Tax Ruling Info Exchange

On December 2, the OECD released the first analysis of individual countries’ progress in spontaneously exchanging information on tax rulings in accordance with Action 5 of the BEPS package of measures released in October 2015. The first annual report on the exchange of information on rulings evaluates how 44 countries,… – Continue reading

OECD approves the 2017 update to the OECD Model Tax Convention

On November 21, 2017, the OECD Council approved the contents of the 2017 Update to the OECD Model Tax Convention. The 2017 Update primarily comprises changes to the OECD Model Tax Convention and related commentary that were developed through the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project including changes… – Continue reading

Brunei Signs OECD’s Multilateral Tax Compact

Brunei has become the 113rd signatory to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, signing the pact at the OECD headquarters on September 12. The Convention is touted by the OECD as “the most powerful instrument for international tax cooperation.” It provides for all forms of administrative… – Continue reading

Black money: Switzerland finds India’s data security laws ‘adequate’ for auto-sharing banking info

The notification follows hectic parleys between India and Switzerland for introduction of AEOI (Automatic Exchange of Information) under guidance of G20, OECD (Organisation for Economic Cooperation and Development) and other global organisations. Switzerland found India’s data security and confidentiality laws “adequate” for entering into an automatic exchange of information pact,… – Continue reading

EU challenges Trump on tax avoidance ahead of G20 summit

The European Union has published a letter to EU heads of state, laying down a direct challenge to the Trump administration, on the issues of tax avoidance ahead of the G20 summit this weekend. The joint letter, sent by European Commission president Jean-Claude Juncker and European Council president Donald Tusk… – Continue reading

BEPS: Mauritius inks multilateral convention on tax

Mauritius has signed the Multilateral Convention to Implement Tax Treaty Related Measures to prevent Base Erosion and Profit Shifting (MLI). Once ratified, the MLI will affect as many as 23 tax treaties entered into by this island nation, which has been an important jurisdiction for routing investments into India. Interestingly,… – Continue reading

Better tax system identifies €85bn in additional tax revenue

OECD lauds major progress made €85 billion in additional tax revenue has been identified thanks to progress in creating a fairer and more effective international tax system, the OECD said today. The moves include increasing efforts to close down loopholes, improve transparency and ensure that multinational enterprises pay tax where… – Continue reading

Voices UN seeks a broader transfer pricing role

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