Category: OECD

The Advantages of Enacting a Patent Box Regime

Many countries have enacted a patent box regime in order to spur innovation and create domestic manufacturing jobs. Simply stated, a patent box regime provides a lower tax rate on income from the exploitation of patented goods than for other income. Among the countries that have patent box regimes are… – Continue reading

Not international business as usual

BARBADOS’ OFFSHORE FINANCIAL SERVICES SECTOR is again under threat. The Organisation for Economic Cooperation and Development (OECD), G20 and the European Union (EU) are acting in concert, armed with the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard (CRS). Once implemented, the confidentiality which once protected financial… – Continue reading

Moscovici resolute on common corporate tax base

EU commissioner urges member states to ensure fair share of tax is paid EU economics commissioner Pierre Moscovici reiterated his commitment to re-launch the Common Consolidated Corporate Tax Base yesterday, urging all EU member states to ensure that companies pay their fair share of tax. Speaking following a meeting of… – Continue reading

Malta remains against tax harmonization

Speaking at an informal meeting of the Economic and Financial Affairs (ECOFIN) in Luxembourg, Finance Minister Edward Scicluna once again expressed Malta’s opposition to tax harmonization. “Taxation remains a sensitive area for Malta, not only because of its obvious role in the revenue collection process, but also as an important… – Continue reading

PwC makes acquisition for high speed FATCA and CRS reports

PwC has acquired software company Ellis Financial Systems in a bid to more rapidly meet new tax information reporting required under such regimes as the Foreign Account Tax Compliance Act (FATCA). It has been re-named PwC Tax Information Reporting, and will operate from London. The acquisition represents one of many… – Continue reading

Tax evader crackdown could reduce offshore banking options for expats

An initiative intended to catch tax dodgers could have a negative impact on those with perfectly legitimate bank accounts. Tax expert Howard Bilton offers advice The draconian Foreign Account Tax Compliance Act (FATCA), introduced by the US Government to tackle tax evasion by its citizens, has already affected Britons living… – Continue reading

Underground Economics Korea’s Underground Economy Places 6th among OECD Member Countries

Policies are urgently needed for the legalization of the underground economy,” said Representative Oh Je-se of the New Politics Alliance for Democracy, who belongs to the Planning and Financial Committee of the National Assembly on Sept. 10. Rep. Oh added that Korea places sixth among OECD member countries in terms… – Continue reading

The Case For A Territorial Tax Regime For Curaçao

Recently the Curaçao Minister of Justice, Mr. Nelson Navarro, approved the so-called Investor’s Permit to accommodate bonafide high net worth persons and entrepreneurs who seek admission to Curaçao. The purpose of the Investor’s Permit is for the investor to provide real economic benefit to Curaçao by increasing employment opportunities and… – Continue reading

Malaysia Resolving International Tax Disputes

Introduction Shaped three decades ago by the then Prime Minister, Tun Dr. Mahathir bin Mohamad, Vision 2020 outlined Malaysia’s goals in becoming a fully developed nation. With the country’s move towards achieving this ‘Malaysian dream’, more Malaysian companies are venturing and investing outside of Malaysia. The increase in trade transactions… – Continue reading

Cyprus: The New Protocol To The Cyprus–South Africa Double Taxation Agreement

On April 1, 2015, Cyprus and South Africa signed a Protocol amending their existing double taxation agreement (“DTA”), which was signed in 1997 and has been in force since December 8, 1998. At the time the original DTA was concluded, dividends arising in South Africa were not subjected to South… – Continue reading

The Implications for International Tax Planning From the Looming Fiscal Crisis

The international financial sector faces a perilous future. Major challenges loom over an uncertain global economy, while a decidedly negative political climate poses an existential threat to the offshore financial community. With each passing year, thanks to demographic changes and poorly designed fiscal policies, politicians from high-tax nations will be… – Continue reading

Indonesia and the Netherlands sign Protocol to amend existing Tax Treaty

On July 30, 2015, the Netherlands and Indonesia signed a protocol (the “Protocol”) amending an agreement between the Government of the Kingdom of the Netherlands and the Government of the Republic of Indonesia for the avoidance of double taxation and the prevention of fiscal evasion, originally signed on January 29,… – Continue reading

Transfer pricing remains thorny issue for international trade

Multinational companies are facing far more expansive and complex audits by tax authorities fighting over the same pot of profits as budget deficits continue to increase, reports BD Live. An inevitable outcome of efforts globally to prevent tax bases from erosion is double taxation and increased disputes over adjusted assessments… – Continue reading

Antigua-Barbuda takes protest over tax haven listing to Capitol Hill

Antigua and Barbuda’s ambassador to the United States, Sir Ronald Sanders, has written to the mayor of the District of Columbia, Muriel Brower, and several members of the US congress calling for the removal of Antigua and Barbuda from a list of alleged “tax havens”, reports Caribbean News Now. Antigua… – Continue reading

Guernsey: What Guernsey Can Offer Chinese HNWIs’

In September 2014, the Hurun Research Institute published its annual listing of the richest people in China. It showed that IT tycoon Ma Yun had increased his personal fortune during the last year by 500% to $25 billion and in doing so, had climbed to first position on the list…. – Continue reading

New Swiss Banking Norms May Not Help India’s Hunt for Black Money

Switzerland will allow stolen data acquired through official means to form the basis for a request for assistance but will help India only for post-2011 bank accounts, that too as long as Swiss courts don’t interfere Geneva: Switzerland’s proposed changes on treating stolen information have generated much optimism in India… – Continue reading

G20 finance communique: Long on reassurance, light on policy

G20 Finance Ministers and Central Bank Governors released their third communique of 2015 over the weekend. Their rhetoric is notable for the calm statement of positive reassurance on the macroeconomic environment, although the direct policy commitments appear to be light on. In the communique, Ministers and Governors recognised the significant… – Continue reading

Indian Competent Authority Akhilesh Ranjan On BEPS

At the 69th IFA Congress in Basel, Taxsutra’s Arun Giri, accompanied by well known tax expert Mukesh Bhutani, interviewed India’s Competent Authority Akhilesh Ranjan. Mr. Ranjan is leading the country’s charge on BEPS, and offers candid views on various issues including confidentiality of information, possibility of a BEPS outcome that… – Continue reading

Colleen P. Waddell, Managing Director, Outlier Solutions to Speak at the Knowledge Group’s FATCA Event

New York, NY, September 05, 2015 –(PR.com)– The Knowledge Group/The Knowledge Congress Live Webcast Series, the leading producer of regulatory focused webcasts, has announced today that Colleen P. Waddell, Managing Director, Outlier Solutions will speak at the Knowledge Group’s webcast entitled: “Latest Regulatory Developments Under FATCA: Best Compliance Practices Uncovered… – Continue reading

Panama reviews AML, tax info exchange legislation

Panama’s Presidential High Level Commission for the Defense of International and Financial Services (CANDSIF) recently held a meeting to review the country’s progress on improving tax transparency and combating money laundering, reports Tax News. In particular, CANDSIF reviewed legislation passed earlier this year as part of Panama’s commitment to address… – Continue reading

Further developments in the BEPS project

A number of further publications have been released this quarter as part of the Organisation for Economic Co-Operation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) project. These include: The 8 June 2015 publication by the OECD of a package of measures relating to “country- by-country reporting” (relevant to… – Continue reading

Making the invisible visible: Senate inquiry into corporate tax avoidance releases interim report

The inquiry raises some larger and perhaps more challenging questions about Australia’s corporate tax system and what is acceptable and unacceptable tax minimisation. On 18 August 2015, the Senate inquiry into corporate tax avoidance tabled a long-awaited interim report, with the subtitle “You cannot tax what you cannot see”. The… – Continue reading

IRS issues new APA procedural guidance

On August 12 the IRS issued final guidance (Rev. Proc. 2015-40) significantly updating procedures for requesting and obtaining an advance pricing agreement (APA) from the Advance Pricing and Mutual Agreement (APMA) program. All new APA requests will need to be filed under these “new procedures”, however, an APA request may… – Continue reading

Survey: Business leaders would pay more tax for greater clarity

Three-quarters of global business leaders would accept higher taxes in exchange for greater clarity on acceptable tax planning, the Grant Thornton International Business Report has found. The survey of 2,580 businesses in 35 countries noted a significant increase from the last time the question was asked – last year –… – Continue reading

International tax update- September 2015

New Zealand: GST and the digital economy The New Zealand Government has released a Discussion Document regarding the proposal to impose goods and services tax (GST) on online purchases of goods and services from offshore suppliers by New Zealand resident consumers. The publication Taxing by the megabyte: New Zealand’s GST… – Continue reading

The OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters: Mauritius deposits Instrument of Ratification, Acceptance or Approval

Based on the overview of Jurisdictions Participating in the Convention on Mutual Administrative Assistance in Tax Matters as available on the website of the OECD, on August 31, 2015 Mauritius deposited its instrument of ratification, acceptance or approval for the Protocol of the OECD Multilateral Convention on Mutual Administrative Assistance… – Continue reading

Hatch, Ryan again seek answers to Base Erosion, Profit Shifting project concerns

U.S. Sen. Orrin Hatch (R-UT), chairman of the Senate Finance Committee, and U.S. Rep. Paul Ryan (R-WI), House Ways and Means Committee chairman, sent a letter on Tuesday to Treasury Secretary Jack Lew, outlining concerns regarding the country-by-country (CbC) reporting requirements in the works at the Treasury Department. The letter… – Continue reading

Mexico used a ‘strong-arm’ tactic to coax multinational corporations into paying more taxes

Mexico’s government withheld hundreds of millions of dollars in tax refunds owed to Procter & Gamble, Unilever, and Colgate combined as it sought to coax them and other multinationals to pay more income tax locally, according to people close to the talks. After luring foreign companies with corporate tax breaks… – Continue reading

Mexico: International Transactions And Cost-Sharing Limitations In Mexico

International worldwide transactions in Mexico face a weakness as a result of an old and outdated provision which disallows for income tax purposes, the deduction of payments made abroad on a prorated basis with other parties that are not subject to Mexican income tax, such as foreign residents with no… – Continue reading

Cross-Border M&A Is Hot, but There’s a Trap for Tax Planners: Picking the Wrong Way to Value Intangibles Can Irk Authorities

NEW YORK, NY–(Marketwired – Aug 31, 2015) – Cross-border mergers and acquisitions are at their hottest pace since before the financial crisis. In fact, M&A volume was $1.10 trillion in 2014, up from $775.3 billion in 2013 and the highest since 2008. And intangible assets like intellectual property and goodwill… – Continue reading

Taxing multinationals: Patently problematic

Proposals for consistent global rules on company tax cause worries all round CLARITY or chaos? Supporters of the Base Erosion and Profit-Shifting (BEPS) project, being worked on by the OECD, argue that it will bind multinationals to a consistent set of global tax rules, providing them with less licence than… – Continue reading

Global tax reporting: Regulatory challenges loom

Reevaluating reporting options and investmentsSmart choices and targeted investments today may help contain the approaching resource crunch and the long term costs of compliance FATCA has placed tax reporting front and center with management committees of financial institutions, but it represents just the tip of a potentially larger iceberg. Legislation… – Continue reading

Government decides to revise convention of double taxation

Pakistan has decided to revise obsolete convention of double taxation and provision of fiscal evasion convention with the United State of America (USA) aimed at bringing the treaty at par with neighbouring countries, well informed sources told Business Recorder. Pakistan and US signed a convention on the avoidance of double… – Continue reading

Cabinet urges rejection of banking secrecy initiative

The Swiss cabinet has urged parliament to reject an initiative aimed at maintaining banking secrecy for domestic private bank clients. In recent years, Switzerland’s much-vaunted tradition of banking secrecy has been under constant pressure. On Wednesday the government dismissed calls to anchor the protection of domestic Swiss banking secrecy in… – Continue reading

New tax rules could erode financial privacy

Security fears; Global authorities to begin sharing sensitive data If you have a bank account somewhere overseas, that information will make its way back to the Canada Revenue Agency (CRA) in a couple of years. In 2018, international tax authorities will begin automatically sharing financial information under the terms of… – Continue reading

Country-By-Country Reporting: The Transfer Pricing Game-Changer

This month’s feature examines proposals for new tax information reporting requirements for large multinational businesses as part of wider and ongoing changes to the international tax system – proposals which have been described by international tax experts as the most significant development in the field of transfer pricing since TP… – Continue reading

Jersey: A Vital Role Supporting Cross-Border Investment Aspirations

Until recently, demonstrating empirically the value of International Finance Centres (IFCs) to global economies has proven relatively difficult. Despite IFCs being able to point to the high quality of their regulation and the endorsement they receive on a consistent basis from global authorities such as the OECD and IMF, this… – Continue reading

Malta: Taking Up Residence In Malta – January 2015

The Maltese climate, culture, history and lifestyle make Malta an attractive place to live in. The fact that this is coupled with a beneficial tax system for people taking up residence in Malta makes Malta an even more desirable location. Introduction to Malta Situated in the middle of the Mediterranean… – Continue reading