Category: G20

Black money: SC order may impact other tax treaties

NEW DELHI: The Supreme Court’s directive on sharing the names of overseas account holders has raised worries about India’s commitment to the confidentiality clause in various tax treaties and may impact remittances from the US. Any move to make the names public without prosecution may hamper signing of the Foreign… – Continue reading

New Zealand to wait 5 years before joining anti-tax evasion initiative

WELLINGTON, Oct. 29 — New Zealand is to join a global scheme to fight tax evasion by multi-national companies in 2019, Revenue Minister Todd McClay said Wednesday, prompting criticism that he was offering a five-year “tax holiday” for foreign firms. G20 leaders announced the initiative for an automatic exchange of… – Continue reading

Increasing focus on transfer pricing, says Deloitte

KUCHING: Accounting firm Deloitte Malaysia stressed on the government increasing focus on transfer pricing whereby there is a new requirement for taxpayers to declare if one has prepared all the necessary transfer pricing documentations. In the past, one was only required to disclose related-party transactions but there was no requirement… – Continue reading

Countries and Companies Join OECD BEPS Train

The OECD’s Action Plan on BEPS was published in July 2013 to reform the international tax system. The Action Plan identified 15 Actions to address BEPS. Seven of the 15 Action Plan items are now moving out of the station. I. Introduction On September 16, 2014 the OECD, together with… – Continue reading

Michael Potts: G20 NZ’s chance to make a real difference

Brisbane summit an opportunity for change and Australia welcomes its neighbour’s help, says Michael Potts. In a few weeks, Australia will welcome leaders of the world’s major economies to Brisbane for the G20 Summit. Australia invited New Zealand to take part in the G20 during our 2014 presidency. Over this… – Continue reading

Tax treaties behind case-by-case disclosure of foreign accounts

Behind the step-by-step approach in the government’s disclosure of names of foreign bank account holders is the confidentiality clause under the Double Taxation Avoidance Treaty (DTAT) that prevents making public the identity of the account holders. Finance Minister Arun Jaitley had earlier said the names of persons would be disclosed… – Continue reading

Tax justice group exposes corporate tax dodgers

Green Left Weekly and ActionAid will be co-sponsoring a Political Economy Society seminar at Sydney University on October 29 to discuss the case for greater international efforts to combat corporate tax avoidance before the G20 summit. Large corporations systematically avoid paying the statutory level of company tax — a low… – Continue reading

Death of the “Double Irish Dutch Sandwich”? Not so Fast.

On October 14, 2014, the Irish Minister for Finance released proposals as part of the 2015 Irish Budget that would cause Irish incorporated non-resident (“INR”) companies to be treated as tax resident in Ireland beginning January 1, 2015. The goal is to shut down the use of so-called “Double Irish”… – Continue reading

Government is considering interest deduction restrictions for infrastructure

Officials from the Treasury and HM Revenue and Customs (HMRC) have been meeting with representatives of the PPP/ PFI industry to discuss the implications for infrastructure projects of possible restrictions to interest relief.24 Oct 2014 Corporate tax Tax Projects Construction Advisory & Disputes Infrastructure UK Europe In a report on… – Continue reading

Interest deductions: the new war on base erosion

ITR Correspondent • • • The G20 and OECD’s Base Erosion and Profit Shifting (BEPS) project has rarely been out of the headlines during 2014. At the heart of the BEPS project is the assumption international tax rules make it possible for profits to be taxed in countries that are… – Continue reading

Improving Transparency and Combating Tax Avoidance to Top Agenda of Ninth Forum on Tax Administration, on 23-24 October 2014 in Dublin, Ireland

21/10/14-Tax administrations will play a central role as governments move to implement the measures they have agreed to counter offshore evasion and combat tax avoidance by multinational enterprises. Global initiatives like the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project and the move toward automatic exchange of financial account account… – Continue reading

Cash-strapped countries eye trillions held offshore

Foreign structures are tempting targets for governments, says Vanessa Houlder. When governments around the world embarked on a drive to plug tax loopholes in 2012, the urgency of the move was underpinned by rising tensions over austerity and inequality. Widespread public outrage over alleged tax-dodging by wealthy individuals and multinationals… – Continue reading

ATO Commissioner Urges Int’l Collaboration On BEPS

Unprecedented international collaboration is needed to overcome a single-, isolated-country view to tackling base erosion and profit shifting (BEPS) issues, Andrew Mills, Second Commissioner of Australian Taxation Office (ATO) for Law Design and Practice, has said. In a speech delivered at the Second Annual Tax Forum organized by the Tax… – Continue reading

Davis Tax Committee mulls ways to ‘detect and deter’ corporate tax avoidance

The revenue implications for South Africa of ‘base erosion and profit shifting’ by corporate taxpayers are firmly in the crosshairs of the Davis Tax Committee (DTC) and Judge Dennis Davis hinted on Monday that recommendations were being considered to “detect and deter” tax-avoiding financial flows. Speaking at a G20 study… – Continue reading

Combating tax evasion: Council agrees to extend automatic exchange of information

The Council agreed last tuesday, at a meeting of the Economic and Financial Affairs Council , on a draft directive extending the scope for the mandatory automatic exchange of information between tax administrations, enabling them to better combat tax evasion and to improve the efficiency of tax collection. The proposal… – Continue reading

Strong rules on transfer pricing on agenda in many countries

AMONG several proposals for tax reform, the director-general of the Revenue Department has said the agency would propose an amendment to the Revenue Code concerning transfer pricing, aiming to provide greater clarity on the determination of fair transfer prices. The director-general has indicated that in past years many multinational companies,… – Continue reading

Harper Government Strengthens Tax Collaboration with India

Minister Findlay meets with Indian counterpart during trade mission to India DELHI, INDIA–(Marketwired – Oct. 15, 2014) – Canada Revenue Agency The Honourable Kerry-Lynne D. Findlay, P.C., Q.C., M.P., Minister of National Revenue, met today with Nirmala Sitharaman, India’s Minister of State for Commerce and Industry and Minister of State… – Continue reading

International tax avoidance: Is it eroding Canada’s tax base and how should we respond?

TORONTO , Oct. 2, 2014 /CNW/ – Aggressive international corporate tax avoidance by multinational corporations has become the subject of intense political scrutiny. U.S. politicians have called out some American multinationals, including Apple, Amazon, Starbucks and Google, for relocating profits abroad to avoid U.S. taxes. More recently, politicians accused Burger… – Continue reading

OECD releases finalised proposals on key tax base erosion concerns

Introduction Action 1: the digital economy Action 2: hybrid mismatch arrangements Action 5: harmful tax competition Action 6: preventing tax treaty abuse Action 8: guidance on transfer pricing and intangible assets Action 13: transfer pricing documentation and country-by-country reporting Action 15: developing a multilateral legal instrument Next steps Introduction On… – Continue reading

BEPS, Broken Promises, and What the OECD Can Learn from the WTO About Dispute Settlement Procedures

The question has often arisen whether “international law” is an oxymoron – whether “obligations” in income tax treaties and other international agreements are really binding upon the parties, when they are not buttressed by some sort of enforcement mechanism. That question has never been more relevant in the tax world… – Continue reading

Worldwide: OECD Releases First BEPS Recommendations To G20 In Accordance With Action Plan

As a part of the OECD/G20 project to combat base erosion and profit shifting (“BEPS”), the OECD released the first set of reports and recommendations on September 16, 2014. These reports address seven of the actions described in the 15-point action plan to address BEPS published in July 2013 (the… – Continue reading

Canada: OECD Issues Work On BEPS Actions

The Organization for Economic Cooperation and Development (OECD) has released the first components of its comprehensive plan for creating an agreed set of international rules for fighting base erosion and profit shifting (BEPS) and ending opportunities for double non-taxation. The four model legal instruments and three reports are the first… – Continue reading

Kenya: KRA After Sh30 Billion in Audit of Companies

The taxman is willing to “negotiate and strike a balance” with multinationals being audited for transfer pricing misconduct, a drive it says has a potential to realise over Sh30 billion. The Kenya Revenue Authority told a workshop organised by the Association of Chartered Certified Accountants in Nairobi that this will… – Continue reading

The Marzen decision: a typical example of BEPS

On June 10, 2014, the Tax Court of Canada (“TCC”) delivered its most recent decision on transfer pricing, one which involved a Barbados structure. In Marzen Artistic Aluminum Ltd. v. The Queen[1] (“Marzen”), Justice Sheridan upheld the Canada Revenue Agency’s (“CRA”) transfer pricing adjustment as well as the penalty under… – Continue reading

Washington resists Hockey’s tax crackdown on Silicon Valley giants

OHN KEHOE The global tax plan being pursued by Australia as G20 president, to compel low-tax paying multinationals such as Google and Apple to ­contribute more revenue to government coffers, could be derailed by political resistance in the United States. A prominent US senator in congress who would likely become… – Continue reading

Bernard Hickey: War on the high-tech dodgers

We pay our taxes. Why won’t they? It’s the topic every tax official and finance minister in the developed world is talking about and acting on, yet we hear little about it in New Zealand. Cracking down on tax avoidance by the world’s biggest technology companies – among them Google,… – Continue reading

Big business ‘shirks’ fair share of tax load

Almost a third of Australia’s largest companies are paying less than 10¢ in the dollar in corporate tax, a report that exposes a gaping hole in government revenues over the past decade shows. As Australia prepares to host world leaders at the G20 summit in Brisbane in November, where a… – Continue reading

Osborne plans crackdown on tech groups with new anti-avoidance rules

High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. http://www.ft.com/cms/s/0/f0564d62-4803-11e4-b5ad-00144feab7de.html#ixzz3EsBYd5vW Technology companies “that go to extraordinary lengths” to cut their tax… – Continue reading

Taxman targets multinational profit stripping

Inland Revenue has gone shopping for a database to help it fight erosion of the tax base and “profit stripping” by multinational corporations. The database will help the taxman to independently assess the level of profitability companies should be returning for tax purposes by benchmarking the prices multinationals charge their… – Continue reading

Germany may close foreign ‘patent box’ tax loophole: report

German Finance Minister Wolfgang Schaeuble is working on closing a tax loophole whereby German firms use so-called “patent box” tax breaks available abroad on profits generated from patented research to minimize tax bills, according to a magazine report. Business weekly Wirtschaftwoche said a potential new restriction on the practice, similar to one in… – Continue reading

Trillion Dollar Scandal – the biggest heist you’ve never heard of

The World Bank analysed the world’s biggest corruption scandals over that past two decades. Seventy per cent involved anonymous shell companies Take a guess at how much is lost to developing countries each year through international corruption? $1 billion, maybe $10? Even more? The shocking truth is that $1trn a… – Continue reading

OECD: tax avoidance rules must avoid “collateral damage” on fund management industry

The fund management industry could be exempted from new global rules intended to combat tax avoidance by multinational companies if further work finds that they may “hamper legitimate transactions”, according to the Office for Economic Cooperation and Development (OECD).26 Sep 2014 Corporate Tax Corporate tax Tax Disputes and Investigations Investment… – Continue reading

The Skinny on Corporate Inversions

Corporate financial accounting and taxation are complex subjects. For this reason, many people tune out when issues that involve corporate tax practices rise to the level of public debate. Unfortunately, many legislators shy away from these issues for similar reasons. But while corporate taxation can be mind-bogglingly complex, nontax experts… – Continue reading

Tax avoidance under scrutiny

European Union Tax Commissioner Algirdas Šemeta has welcomed a raft of new measures to combat international tax avoidance, in agreement between the finance ministers of the G20 at a meeting in Cairns, Australia. The ministers have agreed on a several recommendations that were made to address key areas which were… – Continue reading

UK government reveals new tax evasion scheme for multinationals

Global corporations based in the UK will now have to report where they make their profits and pay their taxes to HMRC, the UK government has announced. The new country-by-country reporting template was released this week by the OECD and the UK is the first of 44 countries to officially sign… – Continue reading

UK Chartered Accountants Welcome BEPS Progress

The Chartered Institute of Taxation’s Tax Policy Director has said the “first wave of reports [from the Organization for Economic Cooperation and Development on base erosion and profit shifting] is a significant step forward in the process of modernizing the international tax system, but the test will be getting international… – Continue reading

NZ banks baulking at global FATCA style initiative to combat tax evasion; Lobby group says the later we adopt it the better

All is likely to be revealed on whether New Zealand will be an early adopter of the multilateral follow up to the controversial United States Foreign Account Tax Compliance Act (FATCA) in November, with late adoption something that would please the local banking sector. Either way it’s a question of… – Continue reading