On 3 May 2019, Portugal introduced amendments to Portuguese Taw Law, in accordance with the European Union (EU) Anti-Tax Avoidance Directive (ATAD). ... - Continue reading
The Australian Taxation Office (ATO) on September 27 set out its approach to analyzing transfer pricing issues associated with the use in Australian waters of non-resident owned mobile offshore drilling units such as drill-ships, drilling rigs (including but not limited to submersibles, semi-submersible and jack-up rigs), pipe-laying vessels, and heavy-lift vessels. ... - Continue reading
Denmark’s Ministry of Taxation on 12 September published a draft bill proposing a number of changes to Denmark’s international tax provisions including a requirement to submit transfer pricing documentation together with the corporate income tax return. ... - Continue reading
The EU General Court today released long-awaited rulings in the Fiat and Starbucks tax state aid cases, concluding in both decisions that it is appropriate for the European Commission to assess whether an advance pricing agreement (APA) confers a selective advantage to a taxpayer for state aid purposes by referring to the arm’s length principle. ... - Continue reading
The IFA Congress 2019, held 8-12 September in London, brought together leading international tax and transfer pricing experts from around the world. ... - Continue reading
On September 8, the executive branch of the Mexican government introduced Mexico 2020 tax reform, proposing far-reaching changes to the Mexican income tax, value-added tax, and Federal Tax Code. ... - Continue reading
MOSCOW, Sept. 20 (Xinhua) — The Russian Federal Tax Service (FTS) may stop the automatic exchange of financial information with Britain and its dependencies — the Isle of Man, Guernsey and Jersey, TASS news agency reported Friday, quoting an FTS draft order. According to the news report, the draft order… – Continue reading
A panel of judges in Luxembourg on Tuesday will begin hearing arguments concerning the US tech giant Apple and the world’s biggest tax case. The EU General Court (EGC) will begin hearing the appeals lodged by Ireland and Apple against the EU tax ruling. It has to weigh up whether… – Continue reading
KARACHI: The Federal Board of Revenue (FBR) will tighten noose around offshore illicit money and assets as Pakistanis having undeclared assets abroad are required to file statement by September 30, 2019. “The FBR will launch proceedings against persons having offshore assets on the basis of available data,” an official at… – Continue reading
The Federal Inland Revenue Service (FIRS) has issued the Income Tax (Common Reporting Standard) Regulations, 2019 (CRS Regulations). This follows Nigeria's signing of the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAC) and the Multilateral Competent Authority Agreement (MCAA) on the Automatic Exchange of Financial Account Information, signed by Nigeria on 17 August 2017. ... - Continue reading
New rules mandate officials to refer a suspected case of tax avoidance to a panel of senior officials ... - Continue reading
One in five US citizens living abroad are on the verge of giving up their passports according to a survey published by US tax consultants Greenback. The Greenback survey – which was conducted by more than 3,000 US expats – studies the expat community’s opinions on taxation, citizenship renunciation, and… – Continue reading
France has joined the International Compliance Assurance Programme (ICAP) pilot program, the OECD announced September 16, bringing the total number of tax administrations participating to 18. ... - Continue reading
The governments of New Zealand and Guernsey on September 18 signed protocol to their tax information exchange agreement, the New Zealand government has announced. ... - Continue reading
OECD tax director also criticises State’s slow move to phase out ‘double Irish’ loophole ... - Continue reading
The Automatic Exchange of Information (AEOI) initiative by the Organisation for Economic Cooperation and Development (OECD) will assist the Inland Revenue Board (IRB) in cracking down tax evasion, said Finance Minister Lim Guan Eng. ... - Continue reading
The start of a new European Commission also means setting new political priorities in the EU tax field. ... - Continue reading
German finance minister Olaf Scholz is in the midst of a campaign tour for the social democrats (SPD) presidency. ... - Continue reading
The European Commission today announced that it has opened 39 in-depth investigations to assess whether Belgian “excess profit” tax rulings granted to multinationals between 2005 and 2014 provided benefits that are contrary to EU State aid rules. ... - Continue reading
Despite OECD efforts to encourage countries to more swiftly and effectively resolve of cross-border tax disputes, overall mutual agreement proceedure (MAP) inventory continues to increase, OECD statistics released today revealed. ... - Continue reading
The Internal Revenue Service (IRS) has outlined new procedures for some “accidental Americans,”, giving them the chance to comply with their US tax and filing obligations and in turn qualify for relief from back taxes, penalties and interest. The changes would allow people with less than $2m in net worth… – Continue reading
Nearly 40% of worldwide foreign direct investment (FDI), amounting to $15trn, “passes through empty corporate shells” with “no real business activities”, a study by the IMF and the University of Copenhagen reveals. According to the report, ten economies including Luxembourg, the Netherlands, Hong Kong, BVI, Switzerland, Singapore, Ireland, the Cayman… – Continue reading
A US-born British citizen has started a crowdfunding campaign to stop HMRC sharing her personal information with the US Internal Revenue Service (IRS) under the US Foreign Account Tax Compliance Act (FATCA). Law firm Mishcon de Reya has taken on the UK case for a client who alleges HMRC is… – Continue reading
The preliminary results of an impact assessment reveal that proposals advanced in an OECD-led effort to update the global rules for taxing digital businesses would not create large changes to countries’ existing taxing rights, Pascal Saint-Amans, OECD Director of the Centre for Tax Policy and Administration, said September 11. ... - Continue reading
The Federal Court of Australia on 3 September issued its much-anticipated judgement Glencore Investment Pty Ltd v Commissioner of Taxation of the Commonwealth of Australia [2019] FCA 1432, herein referred to as the Glencore decision. ... - Continue reading
Luxembourg and the US have amended their double taxation convention, updating the exchange of information article to harmonise it with that of the US model income tax treaty and the OECD. US ambassador to Luxembourg Randy Evans and Luxembourg finance minister Pierre Gramegna (DP) on Monday announced the ratification of… – Continue reading
In the past ten years, Switzerland has undertaken significant efforts to combat international tax fraud and tax evasion and to fight for the strict observance of foreign tax laws. In order to do so, a number of tax laws were enacted, allowing Switzerland to comply with international standards issued by the OECD (acting on behalf of the G20). In this respect, Switzerland ratified the Multilateral Convention on Administrative Assistance originally issued by the CoE and the OECD in 1988 and amended in 2011 ("OECD MC"), and it renegotiated numerous Double Taxation Conventions ("DTC"), amongst them also the DTC with Italy, in order to comply with the international standard introduced by the OECD MC in the version of July 2010. ... - Continue reading
The OECD said its initiative to have minimum standards on the collection and exchange of country-by-country (CbC) reports on large multinational businesses has reached 116 jurisdictions and has shown major progress in the delivery of international tax transparency. The OECD’s second annual peer review report on the base erosion and… – Continue reading
Next month, the European Union will revamp its methodology for compiling its anti-money laundering blacklist, after a previous list was blocked by EU governments that objected to the listing of Saudi Arabia and four US overseas territories, EU Commissioner for Justice Vera Jourova told the Financial Times recently.“We have admitted… – Continue reading
Banking details of Indians with accounts in Switzerland have been made available to tax authorities as the automatic exchange of information agreement starts between the two countries. “India will receive information of the calendar year 2018 in respect of all financial accounts held by Indian residents in Switzerland. This will… – Continue reading
The Automatic Exchange of Information mechanism between India and Switzerland is being seen as a major boost in India’s fight against suspected black money stashed abroad A joint team of officials from Central Boad of Direct Taxes (CBDT), Central Bureau of Investigation and other probe agencies, who are looking into… – Continue reading
On June 7, 2017, Canada along with numerous other jurisdictions signed the Organisation for Economic Co-operation and Development’s (“OECD”) Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the “MLI” or “multilateral instrument”). The multilateral instrument is the culmination of work undertaken as part of the OECD/G20 BEPS Project to equip governments with domestic and international instruments to address tax avoidance. ... - Continue reading
The government brought into legislation a specific element of the 2017 OECD guidelines that permits the tax authority to re-characterize an intra-group arrangement. ... - Continue reading
The OECD today released a peer review report judging whether 116 countries and their tax administrations have met standards on the collection and exchange of country-by-country (CbC) reports on large multinational businesses. ... - Continue reading
Brian Jenn, former US Treasury Deputy International Tax Counsel, has joined McDermott Will & Emery’s tax practice as a partner, the firm announced today. Jenn will be based in McDermott’s Chicago office. ... - Continue reading
Georgia, an Eastern European Country, was ranked 6th in the World Bank Group’s 2019 “Doing Business” survey. ... - Continue reading
A bill was introduced to the Mexican Congress on August 21 to tax digital platforms. ... - Continue reading
India will start getting details of bank accounts held by its citizens in Switzerland from September, ending the era of Swiss bank secrecy. ... - Continue reading
Barbados’ removal from the European Union’s (EU) blacklist has been welcomed by the Institute of Chartered Accountants of Barbados (ICAB). During her welcome remarks at the 15th Annual ICAB International Business Workshop, at the Barbados Hilton Resort, ICAB’s Executive Director, Kathy-Ann Hewitt, stated: “We are indeed happy that this change… – Continue reading
Canada and Switzerland on August 8 deposited with the OECD their instruments of ratification for the Multilateral Convention to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS MLI). The BEPS MLI, negotiated by over 100 countries and jurisdictions, updates the existing network of tax treaties and… – Continue reading
The Organisation for Economic Co-operation and Development is going to propose a global minimum tax that would apply country by country before the next meeting of G‑20 finance ministers and central bankers set for 17 Oct. in Washington, DC. G7 leaders announced at their Biarritz summit meeting this week a… – Continue reading
Canada and Switzerland have deposited their instruments of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), the OECD today announced. ... - Continue reading
With effect from 1 January 2019, the Anti-Tax Avoidance Directive (ATAD) I intra-EU hybrid mismatches rules were introduced into Luxembourg’s domestic law. ... - Continue reading
Tens of thousands of British citizens born in the US but only lived there for a few months or years face having their bank accounts frozen as part of a crackdown by the US tax authorities. The Internal Revenue Service (IRS) is ordering British banks to hand over the… – Continue reading
After 20 years of negotiations, the European Union and Mercosur have moved forward with the free trade agreement between the two blocs. ... - Continue reading
In a recent decision, the U.S. Court of Appeals for the D.C. Circuit unanimously affirmed a district court order compelling three Chinese banks (not currently identified) to produce financial records in response to subpoenas issued by U.S. federal prosecutors, including records that were unrelated to the banks' U.S. operations or U.S. correspondent accounts. ... - Continue reading
In 2018, the European Commission (EC) concluded two more investigations into whether the tax ruling practices of Member States breached European Union (EU) State aid rules: the first, a finding of unlawful State aid resulting from tax rulings by Luxembourg in favor of Engie; the second, a rare finding of no aid in respect of the treatment by Luxembourg of McDonald's under the Luxembourg-U.S. double taxation treaty. These decisions are discussed below. ... - Continue reading
French President Emmanuel Macron today confirmed that the US and France have reached a compromise agreement which requires France to refund all digital services tax (DST) paid by multinationals once a new international system for taxing multinationals in the digital sector is in place. ... - Continue reading
The Directorate General of International Taxes of the Federal Board of Revenue (FBR) has started analysing a few potential multinational companies’ cases of transfer pricing where companies are directly involved in shifting their profits outside the country without payment of any taxes. In this regard, Directorate General of International Taxes… – Continue reading
ISLAMABAD: The government has kicked off a far-reaching crackdown against benami assets directing the departments concerned at the federal level and the provincial governments to track benami properties, harvesting the Benami Act, 2019 in the national and global contexts. Prime Minister Imran Khan chaired a meeting on August 20 on… – Continue reading
