Category: Government Bodies

International Tax Disputes: A Ray of Hope

Despite the anticipated tsunami of tax disputes generated by underlying tensions in international taxation, there is reason for hope that appropriate means are being developed to address them efficiently and effectively. Multinational enterprises (MNEs) should be addressing their existing international taxation planning structures in light of coming changes in international… – Continue reading

EU Moves to Close Profit-Shifting Tax Loophole

The European Parliamentary Research Service has estimated that corporate tax-dodging costs the EU between $54.5 billion and $76.4 billion a year. The European Commission has proposed a package of measures to clamp down on corporate tax avoiders that would close a loophole companies have used to shift profits to low-tax… – Continue reading

Singapore’s Income Tax (Amendment) Bill 2016

Upcoming changes to the Exchange of Information framework hints at future adoption of the Organisation for Economic Co-operation and Development’s Common Reporting Standards. The crux of Singapore’s Income Tax (Amendment) Bill 2016, which some think may signal a new chapter in this sphere, may be summarised as follows: The minister… – Continue reading

Secret accounts overseas urged to be reported

Those who have been hiding their income or wealth overseas had better think again, as Korea will soon be exchanging financial information with multiple countries, including tax havens. They are advised to voluntarily report it to the government before the end of March to be given a grace period, said… – Continue reading

The Italian Patent Box and Its (Non-) Compliance with OECD Recommendations

The Italian Patent Box regime largely complies with the OECD recommendations to prevent base erosion and profit shifting. Its non-compliant features offer a brief window of opportunity for companies able to take swift advantage of its wide range of qualifying intangible assets. Many countries have implemented specific IP regimes through… – Continue reading

Mandatory disclosure of tax bills closer as Australia joins OECD push

Australia is one of 31 countries to sign an agreement in Paris to confidentially share tax information on multinational companies in a bid to stamp out tax avoidance. The deal comes as Apple has taken advantage of accounting rules in its local business that could allow it to pay virtually… – Continue reading

Fair Taxation: Commission presents new measures against corporate tax avoidance

Today’s proposals aim for a coordinated EU wide response to corporate tax avoidance, following global standards developed by the OECD last autumn. New rules are needed to align the tax laws in all 28 EU countries in order to fight aggressive tax practices by large companies efficiently and effectively. The… – Continue reading

Why tax technology is critical in 2016

2015 has officially come to an end. Amidst the ending celebrations, packing away of decorations, and last spoonful of dessert, many of us are putting together our work plans and resolutions for 2016. And looking back at last years’ list, there remains one capitalised, un-crossed-off item: BEPS Perhaps your organisation… – Continue reading

Tanzania: Managing Tax Risks – Double Tax Treaties and Implications

Can tax treaty provisions override domestic law?In our last article we defined double taxation as an exposure to tax more than once on the same profit or income. We also highlighted the two types of double taxation i.e. economic double taxation and juridical double taxation and also noted that a… – Continue reading

Seoul preparing to levy ‘Google tax’

x The government plans to exchange financial information on multinational firms doing business here with members of the OECD and G20 countries in order to make them pay appropriate taxes to countries where profits are generated, officials said Thursday. The Ministry of Strategy and Finance said that it will follow… – Continue reading

Are firms with offshore headquarters worth more?

Over the last two decades, an increasing number of companies have chosen to register or establish subsidiaries in offshore financial centres. OFCs are characterized by low taxation, flexible regulations, and secrecy policies (see Fig 1 for the list of OFCs, ranked by Offshore Attitude Index). Many companies with subsidiaries offshore… – Continue reading

EU Seeks Broader Crackdown On Corporate Tax Loopholes

BRUSSELS (Alliance News) – The EU stepped up the fight against corporate tax avoidance Thursday, unveiling proposals including an EU-wide blacklist of international tax havens, as part of a wider clampdown on firms using loopholes to reduce their tax bills. The EU’s executive estimates that member states are deprived of… – Continue reading

India, Armenia sign protocol to amend tax pact

India and Armenia on Wednesday signed a protocol to amend the existing Double Taxation Avoidance Convention between the two countries. “The Protocol amends the Article on Exchange of Information for tax purposes to bring it in line with the updated provisions in the OECD Model,” said a Finance Ministry release…. – Continue reading

Greater tax transparency for multi-nationals a step closer

The South African Revenue Service (Sars) has published additional record-keeping requirements for large multi-national companies which they will have to comply with in future. Many companies have already included some of the required information in their transfer pricing documentation and on their annual tax returns, but there seems to be… – Continue reading

The tax cut we have to have

Australia must not be blown off course from getting a company tax rate closer to 20 per cent. Corporate tax transparency figures released in December by the Australian Taxation Office should not slow momentum. For the first time, the ATO reported the tax affairs of companies with total incomes of… – Continue reading

31 nations sign agreement on exchange of country-by-country transfer pricing reports

In an effort to provide their tax administrations with more tools to combat corporate tax avoidance through transfer pricing, officials from 31 countries today signed an agreement setting out the parameters for automatic exchange of country-by-country reports on large multinational corporations. The agreement — the Multilateral Competent Authority Agreement on… – Continue reading

Africa: EU Anti-Tax Avoidance Package Will Fail to End the Era of Tax Havens, Warns Oxfam

Despite EU intentions to crack down on tax avoidance, the European Commission’s Anti-Tax Avoidance Package does not do what it says on the tin, warns Oxfam, and developing countries will feel the EU’s failure most. The package comes a week after the international NGO revealed that just 62 people own… – Continue reading

Google expected to reveal growth of offshore cash funds to $43bn

Tech company’s 2015 earnings will be announced next week as governments aim to crack down on Google’s controversial tax avoidance arrangements Google is poised to confirm next week that controversial tax structures in Ireland, the Netherlands and Bermuda have boosted its offshore cash mountain to more than $43bn (£30bn), figures… – Continue reading

Global fight against corporate tax avoidance takes off

NEW DELHI, JANUARY 26:Ministers and top tax officials from more than 30 countries including India will sign an international agreement on Wednesday to significantly advance the fight against corporate tax avoidance. This agreement – Multilateral Competent Authority Agreement (MCAA) – will be signed at the OECD in Paris, sources said…. – Continue reading

Central Bank Props up Offshore Yuan in Hong Kong

The People’s Bank of China supports the country’s currency and fends off short sellers in the world’s largest overseas yuan market (Beijing) – The offshore yuan market in Hong Kong has been shaken to the core by weeks of volatility that analysts blame on strong intervention by China’s central bank…. – Continue reading

IRS Still Hunts Offshore Accounts As More Foreign Banks Sign Deals With U.S.

With the web of FATCA information exchanges, whistleblowers, cooperating witnesses, and other sources, the IRS and Justice Department have a wealth of information at their disposal. They have warned offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with… – Continue reading

Irish tax advantages may be banned under new EU rules

Ireland will be forced to ban many of the tax advantages it offers multinationals under proposals to be published by the European Commission tomorrow. This is the first step in an effort to have all EU countries introduce similar tax rules to prevent companies in the 28 member states avoiding… – Continue reading

Europe cracks down on tax dodgers

Directive follows a series of high-profile tax cases involving Google, Apple and others. Rampant corporate tax dodging and sweetheart deals that cheat governments and skew markets, have prompted the European Commission to unveil a new directive Thursday. The proposed legislation follows a quick succession of tax rulings, settlements and investigations… – Continue reading

IRS Adds More Foreign Banks To Disclosure Blacklist

The US Internal Revenue Service (IRS) has added more banks to the swelling list of financial institutions involved in tax avoidance. Customers of these banks owning up to past financial indiscretions under the Offshore Voluntary Disclosure Program (OVDP) face penalties based on balances over the past eight years. Penalties for… – Continue reading

BEPS project: most Indian MNCs see double taxation going up in short term

NEW DELHI, JANUARY 26:A majority of Indian multinationals see the implementation of base erosion and profit shifting (BEPS) project of the Organisation for Economic Cooperation and Development leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting… – Continue reading

Deloitte’s BEPS survey: Quite an eye opener

NEW DELHI, JAN 25: A majority of Indian multinationals see the implementation of OECD’s BEPS project leading to increase in double taxation and compliance burden for them, an India-specific BEPS survey by Deloitte India has revealed. This is interesting given that one of the objectives of OECD’s Action Plan on Base… – Continue reading

Intellectual property taxation in post BEPS era

On 5th October 2015, the OECD released its final reports setting out the action plan on Base Erosion and Profit Shifting (BEPS) project, thus concluding the two year project which started at the behest of G20 countries in 2013. The reports are aimed at suggesting the measures to reform the… – Continue reading

‘Philippines should demand Thailand’s compliance with WTO cigarette ruling’

The Philippines should compel Thailand to abide by the World Trade Organization’s (WTO) ruling on the cigarette-tax case, after Bangkok slapped tax-evasion charges against Philip Morris Thailand (PMT), a legal expert said over the weekend. Lawyer Anthony Abad, who was part of the Philip Morris Philippines legal team that won… – Continue reading

Cyprus Yacht Registration – New Preferable VAT Treatment

A. INTRODUCTION On the 13th of March 2012, the Cyprus VAT Authority has launched a scheme making Cyprus one of the most attractive EU jurisdictions for yacht registration. According to this scheme, a Cyprus company can enter into a lease-sale agreement of a yacht with a third party, paying VAT… – Continue reading

Budget 2016: Budget may ease rules for offshore fund managers moving to India

In a move to woo offshore fund managers to locate in India, the Union Budget for 2016-17 is likely to relax conditions for them to avail of tax exemptions. Budget 2015 had announced some exemptions by amending the permanent establishment (PE) norms. The rules were changed to the extent that… – Continue reading

Isle of Man resists offshore ownership register beneficial ownership

The Isle of Man has refused London’s call to reveal the ownership of thousands of offshore companies, joining other UK Overseas Territories in resisting David Cameron’s transparency push. The Isle of Man told the Financial Times it is a “red line” issue, joining jurisdictions including Bermuda and the Channel Islands… – Continue reading

Can new guidelines get Nigerians into tax net?

The Federal Inland Revenue Service (FIRS) which is now saddled with the onerous task of getting alternative sources of revenue for the federal government has since adopted a stick and carrot approach to bringing tax payers into the tax net. Assistant Editor, Nduka Chiejina looks at the issues contained in… – Continue reading

Gulf’s proposed 5% VAT may translate into more than 10% hit on net income: EY

The Gulf countries’ proposed 5% value added tax (VAT) may translate as more than a 10% hit on net income, unless tax efficiencies are improved, according to Ernst and Young (EY). “A 5% rate may not sound like a lot, but if it ends up as an additional cost on… – Continue reading

TAX DEPT INKS SEVEN NEW TRANSFER PRICING PACTS

The new advanced pricing agreements cover sectors like investment advisory, IT enabled services and manufacturing In the current fiscal year, which is the third year of APA programme, 30 agreements have been signed so far. As part of efforts to reduce tax disputes related to international transactions carried out by… – Continue reading

Google Strikes Deal With U.K. Tax Authority

DAVOS, Switzerland—Google said Friday that it has struck a deal with U.K. authorities that will settle a tax dispute and boost its corporate taxes in Britain, part of a broader effort by European governments to wring more out of big firms in the tech sector. As part of the settlement,… – Continue reading

Extreme Global Inequality Is Out of Control – Something Must Be Done

Coinciding with the World Economic Forum in Davos this week Oxfam has issued a report – entitled An Economy for the 1% – outlining how wealth inequality has grown to the stage where 62 of the world’s richest people own as much as the poorest half of the world’s people… – Continue reading

BEPS rules to be made compulsory from 1 April

India to change laws in Union Budget to make country-by-country reporting mandatory for Indian multinationals New Delhi: India will change laws in the upcoming budget to make country-by-country reporting mandatory for Indian multinationals to ensure they follow so-called base erosion and profit shifting (BEPS) guidelines. The norms were announced in… – Continue reading

EU to clamp down on corporate tax avoidance schemes

Multinational companies are facing severe constraints on their ability to avoid taxes on their activities in Europe as regulators seek to close loopholes laid bare by the LuxLeaks scandal Pierre Moscovici, the EU’s tax policy chief, will set out plans next week to curb practices such as using debt interest… – Continue reading

Ghana To Review Tax Expenditures

The International Monetary Fund (IMF) has welcomed the Ghanaian Government’s fiscal consolidation efforts, including its various revenue-raising initiatives. The Government is seeking to implement an adjustment of two percent of gross domestic product (GDP). This would bring the country’s deficit to about 5.3 percent of GDP in 2016. Over the… – Continue reading

Mauritian Info Exchange Under CRS To Begin In 2018

The Mauritius Revenue Authority (MRA) has confirmed the first exchanges of information under the Common Reporting Standard will now take place from September 2018, rather than September 2017. The OECD’s CRS, the new global standard for automatic exchange of information for tax purposes, obliges all participating countries and jurisdictions to… – Continue reading

Attorney sentenced to two years in prison for tax evasion

A Sacramento federal judge on Thursday sentenced a former West Sacramento attorney to two years in prison for a “sophisticated” tax-evasion scheme. According to prosecutors, James Stewart Richards, 69, owed federal income taxes between 1994 and 2003 totaling $170,000. Not only did he not pay taxes, but he went to… – Continue reading

HMRC tax dispute specialist joins global alliance of lawyers

London-based international law firm Edwin Coe has become a member of a global alliance of lawyers spread across 41 countries. The International Alliance of Law Firms, founded in 1990, already has 60 member firms in EMEA, the US, Latin America, Canada, and Asia-Pacific. Its website describes itself as “an international… – Continue reading

Tax-dodging by the superrich is driving global inequality, Oxfam says

Tax dodging by the super-rich is one of the main drivers of global income inequality and must be sharply curtailed, according to a new report from the global nonprofit Oxfam. Citing research by Berkeley economist Gabriel Zucman — a protégé of Thomas Piketty, author of the global bestseller on inequality,… – Continue reading

European Commission plans threaten change to Irish tax system

Ireland’s insistence that it is not a tax haven and that in fact other EU countries have tax regimes that facilitate tax dodging by multinationals will be borne out by a study to be released next week. But while this will be good news to Finance Minister Michael Noonan a… – Continue reading

Infrastructure could suffer ‘collateral damage’ from international tax changes, experts say

FOCUS: Major infrastructure projects and other purely commercial transactions could suffer collateral damage from proposals to reform the international tax system and prevent avoidance by multinationals. Rising tax costs could put additional strain on the viability of key projects. Infrastructure projects are capital intensive and often have a high level… – Continue reading

The hidden wealth of nations

India’s biggest source of FDI is India itself, money departing on a short holiday to a tax haven and then routed back as FDI. Will the government muster up the political will to clamp down on the tax-allergic business elite? This could be a bumper year for the ever-lucrative tax… – Continue reading

Multinationals may have to provide global income, tax details to taxman

Budget to implement some of OECD’s standards on profit-shifting NEW DELHI, JANUARY 21:Large multinational enterprises (MNEs) may be required post-Budget to furnish to Indian tax authorities information on their global incomes and taxes. This move — a fallout of India agreeing to OECD’s Action Plan on Base Erosion and Profit… – Continue reading