OECD Announces a Public Consultation for Global Minimum Tax Rules
OECD announces a request for comments on its Global Anti-Base Erosion (GloBE) proposal. ... - Continue reading
Category: Government Bodies
India launches Income Tax information portal
The portal is a repository of policy and technical circulars and guidance issued by the Central Board of Direct Taxes. In an attempt to reach out to financial institutions and account holders, the Central Board of Direct Taxes has created an exchange of information portal on the income tax department… – Continue reading
Indirect linkages to Tax Havens
According to the most current Federal Tax Compliance Research Report, there is an estimated US Net Tax Gap (Tax Not Collected) of $406 Billion. ... - Continue reading
Impact of Canada’s ratification of the MLI
The MLI enters into force for Canada from December 1, 2019. ... - Continue reading
OECD seeks feedback on the effectiveness of 13 countries’ cross-border tax dispute resolution processes
Taxpayers are invited to submit comments on their experiences by December 16 through filling out a taxpayer input questionnaire. ... - Continue reading
OECD releases 2500+ pages of public comments to its pillar one “unified approach” for taxing multinationals
The OECD on November 15 published more than 300 comment letters that respond to its request for feedback on the Secretariat’s proposal for a “unified approach” to pillar one. ... - Continue reading
Brexit: Claims about EU tax rules fact-checked
Should Brexiteers rejoice for tax-wise benefits following the disinvolvement of the EU? Let's see here. ... - Continue reading
RenTech’s Billion-Dollar Tax Cloud Darkens After IRS Ruling
A little-noticed decision by the Internal Revenue Service’s appeals unit may spell trouble for legendary investor Jim Simons, who’s embroiled in a multibillion-dollar tax dispute with the agency. ... - Continue reading
Canada: Treaties Impacting On Taxation: A Canadian Tax Lawyer’s Perspective
Taxation has become an increasingly global issue as people, money and property move freely across borders. ... - Continue reading
Nearly a million Canadian bank records sent to IRS
Number of government transfers of records of bank accounts held by Canadian residents to U.S. has been rising ... - Continue reading
OECD invites public inputs on Global Anti-Base Erosion proposal
Bad news for multinational corporations and international businesses : OECD could implement a new law which would require them to pay at least a minimum corporate tax in countries concerned. ... - Continue reading
Will Samsung, Hyundai have to pay digital tax overseas?
Big changes ahead : Samsung Electronics, LG Electronics and other top-tier South Korean companies might have to pay corporate taxes even in countries where they have no physical presence. Here's how. ... - Continue reading
EU to remove Belize from tax haven blacklist this week
European Union finance ministers are set to remove the Central American country of Belize from the bloc's blacklist of tax havens in a meeting this week, an EU document said. ... - Continue reading
Cyprus: Substance – From Corporate Tax Perspective And Other Factors
Substance is vital when it comes to the tax residency of companies and their management and control aspect. ... - Continue reading
Ukraine, U.S. ratify agreement on FATCA de-offshorization
The bill foresees that the Ukrainian banks will open information about the accounts of U.S. citizens in this country; Ukraine, on the other hand, will not be able to get the respective information about Ukrainian accounts in the States The Verkhovna Rada of Ukraine has passed the document about ratification… – Continue reading
Canada: OECD Releases Proposal For “Unified Approach” Under Pillar One For Addressing Taxation Of The Digital Economy
On October 9, 2019, the Organisation for Economic Co-operation and Development (OECD) issued its proposal for addressing the tax challenges of the digital economy. ... - Continue reading
Australia: Simplified Transfer Pricing Record Keeping Options In Australia
Australian entities that meet certain requirements can shortcut the usual lengthy and expensive transfer pricing record keeping process. ... - Continue reading
FBR asks UAE to share details of Pakistanis hiding behind Iqama status
Chairman Federal Board of Revenue (FBR) Shabbar Zaidi on Monday wrote letter to UAE authorities and asked for devising mechanism to share details of Pakistanis who are hiding behind Iqama based residential status to evade taxes. In a letter written to Ministry of Finance UAE by the Chairman FBR Shabbar… – Continue reading
OECD is not the right place to reform international tax rules
On October 9, the Organisation for Economic Co-operation and Development secretariat published its proposed ‘unified approach’ to reform international tax rules, seeking to address the tax challenges of digitalisation. ... - Continue reading
EU Advocate General considers Bulgaria’s refusal to exempt dividends paid to a Gibraltar companies from withholding tax
The Advocate General (AG) in an opinion issued 24 October (Case C-458/18) stated that a company incorporated in Gibraltar and subject to Gibraltar corporation tax cannot be considered to be a “company of a Member State” within the meaning of the parent-subsidiary directive (Directive 2011/96). ... - Continue reading
Australians owe record levels of tax: commissioner
Australians are avoiding their tax responsibilities in record numbers. The Australian Taxation Office (ATO) announced at a Senates Estimates hearing that the debt owed by Australians to the tax man has recently hit 45 billion Australian dollars (31 billion U.S. dollars), a record figure, according to the Australian Broadcasting Corporation… – Continue reading
Estimating reliable transfer pricing profit indicators requires use of all available data
Consider two aspects of statistical reliability principles. First, reliability can be measured by the ratio of the selected variable estimate divided by its standard error. ... - Continue reading
Ireland: Irish Budget 2020 – A Roadmap For Irish And International Business
A guide to the Irish Budget 2020 ... - Continue reading
European Union: UAE Removed From EU Tax Haven Blacklist Along With Switzerland
The United Arab Emirates and Switzerland removed from European Union's list of non-cooperative jurisdictions for tax purposes on October 10. ... - Continue reading
OECD director, tax experts, explore proposed “unified approach to pillar one” for taxing multinational groups
Highlights of the “unified approach to pillar one” proposal ... - Continue reading
G20 finance ministers reaffirm support to tax digital companies
G20 finance ministers support taking the 'Unified Tax Framework' a notch higher - Multinational enterprises like Google, Facebook and Amazon with huge customer base to retain share of profits in concerned countries. ... - Continue reading
International tax evasion by EU nationals amounts to US$50B per year
A new study by the European Commission estimates European Union member states lost US$50.7 billion (46 billion euros), about 0.3% of GDP, in tax revenue in 2016 to international tax evasion by individuals. ... - Continue reading
India: Rules To ‘Secondary Adjustment’ Rationalized And Clarified
The concept of 'Secondary Adjustment' was introduced in Finance Act 2017 by introducing new Section 92CE in the Indian Income Tax Act (the Act) to align transfer pricing provisions with international best practices. ... - Continue reading
Nigeria: Unprecedented Global Drive For Tax Transparency – The Nigerian Perspective
In the last few years, the international tax space has experienced an unprecedented drive to achieve increased transparency in the tax practices of Multinational Enterprises (MNEs) and individuals in order to curb tax avoidance and evasion. ... - Continue reading
Switzerland: Amended Protocol Of Double Taxation Agreement Between Switzerland And USA
On 20 September 2019, Switzerland and the USA ratified the protocol of amendment of their double taxation treaty ("DTA"). ... - Continue reading
US IRS addresses expiration of temporary section 385 debt/equity regs
The US IRS on October 11 released IRS guidance addressing the expiration of debt-equity documentation temporary regulations under code Section 385. ... - Continue reading
Nigeria: FIRS To Deploy E-Filing Platform For Transfer Pricing Related Returns
In 2017, the Federal Inland Revenue Service (FIRS) announced the introduction of six (6) new electronic services. ... - Continue reading
OECD proposal on taxing MNEs to benefit countries like India, say experts
The OECD Secretariat has published a public consultation paper to advance international negotiations ... - Continue reading
What OECD’s tax plan for tech giants means for India
- OECD has proposed that profits of MNCs should be available for taxation in the country where their customers are, irrespective of any physical presence in that market
- A formula should be evolved for such taxation
Mexican 2020 Tax Reform: key international tax proposals
Key tax changes to the country’s tax law primarily inspired by the OECD’s base erosion and profit shifting (BEPS) project ... - Continue reading
EU Council revises its tax blacklist, addresses “two out of three” exception and foreign source income exemption regimes
As suggested by the EU Code of Conduct Group (Business Taxation), on 4 October, the EU Council today adopted a revised EU list of non-cooperative tax jurisdictions (annex I – blacklist) removing the United Arab Emirates (UAE) and the Marshall Islands. ... - Continue reading
Ireland Transfer Pricing Feedback Statement Explained
The Irish Government recently published a Transfer Pricing Rules Feedback Statement which is explained in this article. ... - Continue reading
The Fiat and Starbucks state aid tax cases: an absolute loss for legal certainty.
In late September, the EU General Court released its decisions in two long-awaited state aid appeals: Fiat (cases T-755/15 Luxembourg v Commission and T-759/15 Fiat Chrysler Finance Europe v Commission) and Starbucks (cases T-760/15 Netherlands v. Commission and T-636/16 Starbucks and Starbucks Manufacturing Emea v. Commission). ... - Continue reading
Argentina issues burdensome draft transfer pricing guidance for public comment
Argentina’s tax authority on October 2 launched a public consultation on proposed guidance that includes significant and burdensome changes to the transfer pricing requirements that local taxpayers must comply with. ... - Continue reading
Accidental Americans’ sue France over FATCA disclosure rules
A group representing French-American taxpayers has filed a complaint against France with the European Commission over its compliance with the US Foreign Account Tax Compliance Act (FATCA), in a bid to avoid being blacklisted by French banks starting in January. France is a signatory to an agreement to give the… – Continue reading
EU to remove UAE and Switzerland from tax blacklist
The United Arab Emirates and Switzerland are set to be removed from a European Union blacklist of countries deemed to be tax havens, according to a Reuters report citing an official document. Switzerland has delivered on its commitments, the document said, acknowledging that a tax reform passed last year –… – Continue reading
Paraguay introduces transfer pricing rules
Paraguay, on September 13, enacted special regulations providing for the transfer pricing analysis of intercompany transactions. ... - Continue reading
UK: Ways For UK Businesses And Foreign Investors To Mitigate Uncertainty Around Brexit
The UK remains in the international spotlight in 2019 as the first member of the European Union to signal its intention to exit irrevocably from the Union. ... - Continue reading
Draft “toolkit” aims to help developing countries with transfer pricing documentation
The Platform for Collaboration on Tax – a joint initiative of the International Monetary Fund, OECD, United Nations, and World Bank Group – on September 27 released a draft “toolkit” aimed at helping developing nations design transfer pricing documentation rules. ... - Continue reading
Switzerland moves to end bearer shares
The Swiss government will begin to phase out bearer shares on 1 November in a bid to curb tax avoidance by bearer shareholders. Under the new rules companies no longer issue bearer shares—equity in a company that is owned by whoever holds a physical stock certificate—unless they are a listed… – Continue reading
Ireland must prepare for international tax turbulence
It looks like the world’s leading economies are determined to claim a bigger slice of the global corporate tax pie which will lead to tricky times ahead for Ireland, according to PwC tax policy leader Peter Reilly ... - Continue reading
Jersey: Capital Markets: Listing Jersey Holding Companies
With £184 billion market capitalisation held by Jersey listed companies on global exchanges as of 30 June 2019, this briefing explores why Jersey vehicles remain such a popular choice for taking international businesses to market. ... - Continue reading
EU ready to act alone on digital tax if no global deal in 2020
Ramping up pressure on multinationals accused of paying too little. ... - Continue reading
Important tax changes for home owners from next April
QUESTION: I’m in the process of selling our family home and down sizing to a smaller property. I have just completed the purchase of our new home and we intend to move in soon. Our current home has been on the market for six months but we haven’t been able… – Continue reading
Iceland joins BEPS MLI tax pact
Iceland on September 27 became a party to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI) by depositing its instrument of acceptance of the agreement with the OECD. Iceland is the 89th jurisdiction to join the tax agreement. ... - Continue reading
