The European Commission will propose a draft law next year to stop tax regimes that favour raising corporate debt over equity as it tries to reduce the amount of company loans on banks’ books and to cut companies’ leverage, officials said on Monday, reports Reuters. In most European countries, companies… – Continue reading
The OECD has said that its base erosion and profit shifting (BEPS) project will create policy challenges for Ireland, but the nation should emerge well placed to attract foreign direct investment, reports Tax News. The report states: “Given the strong presence of intellectual property-intensive information technology and pharmaceutical companies in… – Continue reading
The Embassy of the Republic of Latvia has begun operations in Seoul, the capital of the Republic of Korea. The Embassy will be promoting political and economic dialogue between Latvia and Korea especially in support of Latvian businesses and cooperation with potential Korean investors, thereby facilitating access to third country… – Continue reading
China’s State Administration of Taxation (SAT) has been busy during recent months pushing ahead with its own plans to update/revise a series of domestic tax laws and regulations as well as Sino-foreign tax treaties. The most prominent of these changes is a proposed update of Circular Guoshuifa 2009 No.2 (Circular… – Continue reading
One in five corporations with annual profits greater than $100 million paid no tax last year, the Australian Tax Office has revealed. Michael Cranston, one of the ATO’s deputy commissioners, revealed the figure to a Senate hearing into corporate tax avoidance. Corporations avoid paying tax by what is euphemistically called… – Continue reading
Efforts to amend details of new rules on corporate profits raise questions, reports the Wall Street Journal. Nearly 50 governments are set to agree this fall to a new set of rules to clamp down on tax avoidance among multinational corporations. Their chance of success, however, is unclear. If the… – Continue reading
If the anti-corruption march goes ahead on Wednesday, it will be remiss if it doesn’t address one of the key issues of 2015: illicit financial flows. Institutions around the world are committing to combatting these and Unite Against Corruption needs to push the government to take action locally while lobbying… – Continue reading
Since its inception in August 2014, the SMU-TA Centre for Excellence in Taxation has worked tirelessly with industry practitioners, international academics and various key stakeholders to produce its first set of research works. On September 17, the Centre successfully presented its inaugural conference titled “A New Equilibrium in Tax Competition… – Continue reading
The Base Erosion and Profit Shifting (BEPS) Action Plan adopted by the OECD and G20 countries in 2013 recognised that enhancing transparency for tax administrations by providing them with adequate information to assess high-level transfer pricing and other BEPS-related risks is a crucial aspect for tackling the BEPS problem. Against… – Continue reading
On September 17, 2015, the Canadian Border Services Agency (“CBSA“) released a revised D-Memorandum D13-4-5, “Transaction Value Method for Related Persons” (the “Memorandum“), addressing the impact of income tax transfer pricing on the value for duty to be declared on goods imported into Canada. This new guidance will have a… – Continue reading
India must align domestic laws with international treaties A recent ruling of the Punjab & Haryana High Court (HC) in the Serco BPO case has once again underlined the need for consistency between tax policies and the jurisprudence that evolves around it, thus, leaving little to interpretational hazards. The HC,… – Continue reading
In 2013, the Organisation for Economic Cooperation and Development (OECD) released a series of proposed tax measures for eliminating corporate tax structures that shift profits to foreign jurisdictions. This corporate tax practice is commonly referred to as base erosion and profit shifting or BEPS. Towards this, the OECD and G20… – Continue reading
The increasingly international nature of business will lead to complications and disruptions that may plague the future of audit, according to PwC. A recently-released PwC report, Global Tax Transparency and Risk Management – part of the ‘Tax Function of the Future’ series – notes that the number and size of… – Continue reading
Prime Minister Narendra Modi has assured Cyprus President Nicos Anastasiades that he would look into the double taxation agreement to see how he could expedite it and said that Nicosia has always stood by New Delhi on all issues of ‘mutual concern’. “The Cyprus President said that the nation had… – Continue reading
Automatic exchange of information for tax law enforcement purposes started first in Europe with the EU Savings Tax Directive, went international with the US Foreign Accounts Tax Compliance Act, and, from 2017, will go global with the recently-agreed Common Reporting Standard, the subject of this feature. Introduction To The Common… – Continue reading
Pretoria – The constant stream of new data requirements by the South African Revenue Service from South Africa’s major banks is costing the sector millions of rand and affecting the economy and banking costs. Tax heads at the banks raised questions during the recent Tax Indaba in Sandton about the… – Continue reading
Bloomberg BNA’s first transfer pricing conference in Asia—the latest offering in our Global Transfer Pricing Conference series with Baker & McKenzie—could not have been better timed. The day the conference opened, Sept. 17, China issued a revised draft circular on transfer pricing that completely changed the game for multinational companies… – Continue reading
The government in the tiny Swiss canton of Zug has been forced to admit the previously unthinkable: its famously low tax rates, which have attracted a host of companies and celebrities, may have to rise. Facing a series of financial blows — including the effects of a strong Swiss franc… – Continue reading
Honda’s manufacturing plant in India, one of the emerging countries where many Japanese companies are in disputes with local tax authorities. TOKYO — Many Japanese companies operating in emerging countries are grappling with taxation problems they would never face in major industrial nations. Honda Motor, for instance, has gotten embroiled… – Continue reading
The Head of the Maltese Labour Delegation at the European Parliament, Alfred Sant, said that tax competition is needed by peripheral and island states unless there is compensatory mechanism to compensate them for the fact that they don’t have the endowments that other countries have. “Where competitive disadvantages exist, these… – Continue reading
Tax avoidance is a key problem for European countries, with the EU taking several steps to try and limit the ability of businesses to shift their profits to low-tax jurisdictions. Peter Dietsch writes on the nature of the problem and what can be done to tackle it. He argues that… – Continue reading
Hungary’s Minister of State for the Utilization of EU Funds, Balázs Rákossy, has called for a more coordinated EU effort in the fight against tax evasion. Speaking at the 13th G28 taxation forum, Rákossy noted that the recent EU report on the VAT gap revealed that EU states lost theoretical… – Continue reading
Tax competition as such cannot be avoided, but today’s system has reached its limits and led to unwanted side effects. Small firms should not have to bear the tax burden of multinationals that pay very little. Action is needed to harmonise corporate tax practices across Europe, so as to make… – Continue reading
The Minister for the Economy, Investment and Small Business, Dr Chris Cardona attended Malta Day 2015 in Moscow coinciding with the 51st anniversary from Malta’s independence, during which a Maltese-Russian Business Forum was held. Minister Cardona spoke about the good relations Malta has held with Russia, which go back many… – Continue reading
The IRS recently replaced Rev. Proc. 2006-54 for requesting assistance under the Mutual Agreement Procedure (“MAP”) article of U.S. tax treaties, and Rev. Proc. 2006-9 for requesting Advance Pricing Agreements (“APAs”). The new Rev. Procs. (2015-40 and 2015-41, respectively) largely track draft procedures issued in 2013 (Notices 2013-78 and 2013-79),… – Continue reading
Prime Minister Narendra Modi is scheduled to attend the UN Sustainable Development Summit as part of his second visit to the United States. INDIA IS likely to talk on the increased global efforts against tax avoidance and tax evasion at the United Nations later this month. Prime Minister Narendra Modi… – Continue reading
NEW YORK, NY–(Marketwired – September 23, 2015) – With the global implementation of FATCA and anticipation of the Common Reporting Standard (CRS), legal and compliance professionals within the banking industry have never seen such a regulatory overload and focus on ensuring proper compliance processes. As these multi-national regulations become implemented… – Continue reading
The tax office is beefing up efforts to catch international tax cheats by swapping banking information with US authorities. Details of more than 30,000 financial accounts worth over $5 billion held in Australia by US citizens will be provided to US Internal Revenue Services under the first wave of transparency… – Continue reading
BHP Billiton has defended the use of a Singapore marketing hub to minimise its tax payments, saying most of its Australian profits continue to be taxed in its home country. The resources giant, which came under fire earlier this year over allegations of tax avoidance, says its global adjusted effective… – Continue reading
On 31 March 2015, the Austrian Ministry of Finance published a decree dealing with, inter alia, mutual agreement procedures under double tax treaties. Currently, Austria has concluded 85 double tax treaties, all of which contain provisions on mutual agreement procedures (MAPs). However, Austrian statutory law does not provide for procedural… – Continue reading
Action is needed to harmonize corporate tax practices across Europe, according to the European Parliament’s Special Committee on Tax Rulings. The committee said this was the key sentiment voiced during a meeting with finance ministers from Luxembourg, Italy, France, Spain, and Germany on September 22. According to the committee, while… – Continue reading
BHP Billiton has warned any move by Australia to single-handedly combat corporate profit shifting could spark a backlash from other nations that is likely to ultimately harm local companies. Finance director Peter Beaven says while action on so-called base erosion and profit shifting is needed, it must be part of… – Continue reading
The Australian Government has released an exposure draft of the legislation implementing the OECD Standard for Automatic Exchange of Financial Account Information (known as the Common Reporting Standard, or CRS), and an accompanying explanatory memorandum (available here). The draft requires Reporting Financial Institutions to report to the Commissioner of Taxation… – Continue reading
Finance ministers of euro zone’s major economies renewed on Tuesday their commitment to curb multinational corporations’ tax avoidance and called for more consistent rules to reduce “harmful” tax competition. Multinational companies have long been in the sights of European Union authorities because of the way they can legally reduce their… – Continue reading
A report from Italy’s Minister of the Economy and Finance says the annual Italian “tax gap” – the revenue lost due to tax breaks, avoidance, and evasion – totalled EUR91.3bn, or 6.6 percent of the country’s gross domestic product, during the period 2007-2013. This represents a fall from the EUR93.5bn… – Continue reading
Marginal rate ninth highest in 34 OECD countries, pre-budget submission claims Ireland risks deterring high- calibre foreign executives from moving here because of its relatively high tax rates, the Irish Tax Institute has warned. In a pre-budget submission, the institute said Ireland’s marginal tax rate of 52 per cent was… – Continue reading
(Seychelles News Agency) – The Central Bank of Seychelles (CBS) says it is engaging with Barclays Bank Seychelles to ensure that clients have sufficient time to shift their deposits in their offshore bank accounts, following a recent decision by Barclays to discontinue its banking services for non-residents in foreign currencies…. – Continue reading
Measures aimed at ensuring companies disclose more information to authorities Ireland is to become one of the first countries to introduce measures aimed at ensuring multinationals disclose more information to tax authorities. In the upcoming budget, the Government will introduce moves obliging multinationals to draft country-by-country reports on their global… – Continue reading
BY DAVID JESSOP— The Caribbean has just 18 congressional working days from Sunday, September 20 to try to have the U.S. Congress address an act naming 17 Caribbean nations as “tax havens”. If passed without amendment, it could have the effect of reputationally damaging the countries concerned with unpredictable trade,… – Continue reading
It could become more expensive for regulated online poker operators to offer services in the ring-fenced Italian marketplace thanks to a proposal to introduce a new “Digital Tax” beginning January 1, 2017. Economy Undersecretary Enrico Zanetti confirmed that if the tax becomes law, it will be levied on online gambling… – Continue reading
As discussed in the previous edition, due to current worldwide developments including the OECD’s move to curb tax Base Erosion and Profit Shifting (BEPS), tax policy is changing significantly. In Ghana for example, a Transfer Pricing Regulations was passed in 2012 which aimed to ensure that the tax base of… – Continue reading
Companies would save €1bn per year in administrative costs if the European Union adopts a common approach to corporate taxation, EU Economic and Tax Commissioner Pierre Moscovici has claimed. The former French finance minister has posted an article to his online blog calling for a mandatory EU common consolidated corporate… – Continue reading
The reality of preparing global documentation may be expanding from a process of producing one or a small number of clearly defined reports to one of collecting and managing potentially significant amounts of data. This article considers how processes and technology habits may need to change to react effectively to… – Continue reading
There are many Non-Resident Indians (NRIs) from the US that are fearful of being involuntary discovered through the impending Foreign Account Tax Compliance Act (FATCA) disclosures of their Indian accounts by their foreign banks. The US Internal Revenue Service has issued a notice extending the time under which certain transitional… – Continue reading
The OECD Common Reporting Standard (CRS) and FATCA in the United States are long-winded. So the OECD published on August 7 a much shorter and lighter guide: the “Common Reporting Standard Implementation Handbook” (the CRS Handbook). The CRS and FATCA represent a sweeping change toward automatic information exchange and away… – Continue reading
A new wave of global tax compliance regulation is a game changer in the way asset owners and investment management companies report activities. Globalization of financial markets has made it increasingly simple to make, hold and manage investments outside an asset owner’s own tax domicile. A standard on automatic exchange… – Continue reading
The Grand Duchy of Luxembourg is ranked third in the world for the number of financial institutions per-country that have now signed up to report under the Foreign Account Tax Compliance Act (FATCA). IRS figures report 8,525 Luxembourg firms have registered with the FATCA portal, and the total is surpassed… – Continue reading
GCC countries are expected to “closely consider” a project that aims to curb perceived tax avoidance by some multi-national companies, according to an international tax expert. Under intense public pressure and unprecedented media focus, leaders of the G20 countries tasked the Organisation for Economic Co-operation and Development (OECD) to come… – Continue reading
NEW DELHI: Widening its probe into suspected tax evasion and laundering of black money through stock markets, regulator Sebi is looking into illicit ‘arbitrage’ through derivatives trading from offshore locations. Also under the scanner are manipulation through ‘client code modifications’ in the past, although there has been a complete clampdown… – Continue reading
China’s State Administration of Taxation on 17 September 2015 released a discussion draft of proposed guidance relating to “special tax adjustments”—including those concerning transfer pricing—for public consultation. It is anticipated that this guidance could be finalized by the end of 2015, and once final, would replace the existing transfer pricing… – Continue reading
