Category: Base Erosion & Profit Shifting

Barbados OECD compliant

Barbados is no longer under threat of a negative listing by the Organisation for Economic Co-operation and Development (OECD). Minister of International Business and Industry, Ronald Toppin, made this disclosure during an international tax conference with stakeholders in New York on Thursday. Minister Toppin said his Ministry had received confirmation… – Continue reading

Ukraine, Switzerland sign protocol on avoidance of double taxation

Ukraine and Switzerland have signed a protocol on the introduction of amendments to the convention on the avoidance of double taxation with respect to taxes on income and capital, and its protocol, concluded in Kyiv on October 30, 2000. Ukrainian Finance Minister Oksana Markarova and newly appointed Swiss President Ueli… – Continue reading

Ministry to mull over measures against profit shifting

The Ministry of Finance will scrutinize amendments to tax law policy in 2019, centred on some measures aimed at preventing base erosion and profit shifting (BEPS) and restructure tax revenue sources. The information was released at a conference reviewing the finance sector’s performance throughout 2018 and setting forth targets for… – Continue reading

Cook Islands joins coalition to fight tax avoidance

The Cook Islands has joined a coalition of countries aimed at fighting tax avoidance and easing cross-border tax dispute resolution. The country has joined 124 other countries in the Inclusive Framework on base erosion and profit shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) announced earlier this month…. – Continue reading

GOV’T SAYS DUTCH BLACKLIST “UNJUSTIFIED”

Cayman’s leaders return fire on the Dutch government describing its blacklist as “unjustified” and “wholly lacking in fairness and credibility.” In a statement Friday (4 January) the Office of the Premier said the Dutch blacklist does not take into account Cayman’s adherence to international standards for tax transparency nor its… – Continue reading

Bermuda: Economic Substance Legislation Tabled In Bermuda

Continuing its ongoing commitment to the development and maintenance of the very highest standards of economic and financial propriety, the Bermuda Government has tabled legislation that embraces a global initiative to combat base erosion and profit shifting (BEPS). The legislation, which was tabled in the House of Assembly on 7… – Continue reading

IRS gives foreign banks a break in Trump tax law’s new levy

The Internal Revenue Service is giving foreign-based banks with U.S. operations some leeway when calculating a major new international tax aimed at preventing global companies from shifting profits abroad. Multinationals often transfer payments, such as interest or royalties, to their affiliates in low-tax jurisdictions to maximize deductions and minimize tax… – Continue reading

Isle of Man approves law to avoid EU blacklist

The Isle of Man’s parliament has approved tax legislation that will allow the jurisdiction to avoid being put on the European Union’s blacklist. Tynwald gave the green light this week to the Income Tax (Substance Requirements) Order 2018. This means that from January 2019, companies engaging in “relevant activities” will… – Continue reading

Cayman drafts law requiring substance tests for offshore businesses

The Cayman Islands government has published draft tax legislation that will have far-reaching impact for the offshore finance industry operating in the jurisdiction by demanding that certain Cayman-registered companies have an adequate level of economic substance locally. The International Tax Co-operation (Economic Substance) Bill 2018 introduces a substance test for… – Continue reading

Tax reforms will improve UAE’s investment status

Once the UAE fully implements the BEPS minimum standard, it will become a very good location, say tax experts The UAE’s position as an attractive destination for foreign investment will substantially improve once it fully implements minimum standards for base erosion and profit shifting (BEPS), tax analysts said on Saturday…. – Continue reading

Switzerland: Revised Swiss Corporate Tax Reform Will Keep Switzerland A Top Corporate Location

I. The background of the tax reform In connection with the international pressure on the Swiss corporate tax location, especially in relation to the Cantonal exemption of income for holding companies as well as the status privileged companies (“status privilege”) and the need of Switzerland to recover global recognition as… – Continue reading

Is this the end of the road for the EU’s digital services tax?

Ireland, Sweden, Denmark and Germany block digital services tax plan in Brussels. The spectre of a 3pc digital services tax (DST) levied by the EU against multinationals has been vanquished for now after Ireland, Sweden, Denmark and Germany joined forces in what is being heralded as a coup for diplomacy…. – Continue reading

Ireland, Malta Close ‘Single Malt’ Tax Avoidance Structure

Ireland and Malta have agreed to close the “Single Malt” – an aggressive tax planning structure in which some multinational corporations use a company incorporated in Ireland but tax-resident in Malta. The Competent Authority Agreement – entered into as per the provisions of Article 24 (mutual agreement procedure) of the… – Continue reading

Barbados minister foresees OECD compliance by year-end

Barbados is to scrap its international business company (IBC) regime in response to the OECD labeling the policy as “harmful” to competition, and being in breach of rules governing international taxation. Last year the OECD included Barbados on its list of jurisdictions with a “harmful” preferential tax regime, and said… – Continue reading

India-China amends double taxation avoidance treaty

New Delhi, Nov 26 India and China have amended the bilateral tax treaty which will help prevent tax evasion by allowing exchange of information, the Finance Ministry said Monday. The Government of India and the People’s Republic of China have signed a protocol on November 26, 2018, to amend the… – Continue reading

Barbados overhauls corporate tax regime, slashes tax rate on local companies more than 20 per cent

BRIDGETOWN, Barbados, Thursday November 22, 2018 – Barbados will harmonize its domestic and international corporation tax regimes, by December 31, 2018, slashing the tax burden for some local companies by up to 29 per cent. Prime Minister Mia Mottley announced in the Barbados Parliament on Tuesday, November 20, the ambitious… – Continue reading

Switzerland: The Brazil And Switzerland Double Tax Treaty: Why Is It So Significant?

Background The Brazilian and Swiss Governments signed a Double Tax Treaty (DTT) on 3 May 2018. Switzerland is one of the biggest investors in the Brazilian market and Brazil and Switzerland have already signed an Automatic Exchange of Information Agreement, which came into force on 1 January 2018. This new… – Continue reading

PM announces tax ease for businesses

Prime Minister, Mia Mottley has announced a major tax break for local business. In her mini-budget presentation made earlier this year, she had announced that come July 1, corporation tax will increase from 25 per cent to 30 per cent which was expected to raise $57M in a full year…. – Continue reading

Ministers meet with EU, OECD to discuss ending tax watchlist

Deputy Prime Minister and Minister of Finance, K. Peter Turnquest, led a delegation to Brussels and Paris this week, for frank discussions with high-ranking officials within the European Commission and the Organization for Economic Co-operation and Development (OECD) on The Bahamas’ compliance with international standards on tax governance. The meetings… – Continue reading

British Virgin Islands: BVI AEOI Update And Introduction Of Country-By-Country Reporting

As part of the British Virgin Islands’ (“BVI”) ongoing commitment to international tax transparency pursuant to the Common Reporting Standard (“CRS”), the BVI Mutual Legal Assistance (Tax Matters) Act, 2003 has been amended by the BVI Mutual Legal Assistance (Tax Matters) (Amendment) Act, 2018 (the “Amendment Act”). The Amendment Act… – Continue reading

BIBA head confident Barbados can make tax law deadlines

Officials in the international business sector here are in somewhat of a wait and see mode as Barbados continues to make necessary legislative and regime changes governing the sector. This means companies seeking to attract new international business to Barbados have not been as robust in their efforts as they… – Continue reading

OECD comes to PNG’s aid to chase tax dodgers

Internal Revenue Commission is now in partnership with an international auditing organisation to help tackle multinationals that are avoiding paying taxes, Deputy Prime Minister and Treasurer Charles Abel, pictured, says. He said that Organisation for Economic Cooperation and Development (OECD), under its ‘tax inspectors without borders’ programme, would help IRC… – Continue reading

Among wider reforms, Bahamas pledges to enact beneficial ownership bill by year-end

The Bahamas has drafted new legislation to ensure the jurisdiction achieves the right balance of business, economic sustainability, and compliance with international standards. Uppermost among the Bahamas’ priorities include compliance with the OECD and EU criteria on tax governance which has led to the Bahamas implementing sweeping changes to the… – Continue reading

Bahamas ‘Must Address’ Beneficial Owner Access

The deputy prime minister has reiterated that The Bahamas “must address” access to beneficial ownership information for all corporate entities domiciled in this jurisdiction. KP Turnquest said the Government was looking to the Register of Beneficial Owners Bill 2018 as the solution, although beneficial ownership will not be publicly available…. – Continue reading

NBR to set up tax unit for foreign cos

National Board of Revenue has decided to set up a separate unit to handle income tax files of foreign companies operating in Bangladesh. The decision was taken responding to a proposal of the European Union for establishing a separate NBR unit for providing hassle-free services to foreign taxpayers. EU came… – Continue reading

FIRS Publishes Nigeria’s Revised Transfer Pricing Regulations

Federal Inland Revenue Service has published Nigeria’s revised Transfer Pricing Regulations (NTPR). The NTPR is effective for basis periods commencing after 12 March 2018 and incorporates BEPS outcomes and suggestions from The African Tax Administration Forum. The NTPR includes significant penalties for non-compliance (a) failure to file TP declaration =… – Continue reading

Government loses huge tax revenue

Ghana loses significant tax revenue through the deliberate manipulation of the tax system by big corporate entities and multinational companies, the Senior Minister, Mr Yaw Osafo-Maafo, has said. He described the situation as worrying and tasked the Ghana Revenue Authority (GRA) to go after those companies and prosecute them if… – Continue reading

Malaysia To Phase Out ‘Harmful’ Tax Regime

Malaysia has suspended its MSC Malaysia tax regime, pending changes to bring it into line with recommendations from the OECD’s Base Erosion and Profit Shifting initiative. Under the regime, domestic and foreign information and communication technology-related businesses can apply for “MSC Malaysia Status,” which allows them to benefit from tax… – Continue reading

A Caribbean Perspective: Tax Rules We Can’T Meet, Unity We Must Not Avoid

The financial services sector of Caribbean jurisdictions – and other parts of the developing world – have been under continuous assault by the European Union (EU) and the Organization for Economic Cooperation and Development (OECD) since the mid-1990s. This assault will peak again in a month’s time when financial institutions… – Continue reading

BEPS Project Has Triggered Near-Global Tax Reform: OECD

The OECD has committed to providing proposals to fix the taxation of the digital economy by 2020, in an update to G20 leaders on international efforts to mitigate base erosion and profit shifting (BEPS). In the newly released Second Annual Progress Report of the OECD/G20 Inclusive Framework on BEPS, the… – Continue reading

Profit shifting a regional issue: Palaso

Profit shifting by large companies is a regional issue that can be addressed through improved information sharing between tax authorities of economies, says Internal Revenue Commission commissioner-general Betty Palaso. She said this at the opening of the Advancing Base Erosion and Profit Sharing (BEPS) and Automatic Exchange of Information (AEOI)… – Continue reading

OECD to help Pakistan implement world tax standard

ISLAMABAD: The Organisation of Economic Cooperation and Development (OECD) on Friday announced that they launched new programme to support Pakistan in implementing new international tax standards. According to statement issued by the OECD after holding three days talks with Pakistani authorities stated that as part of a mission held from… – Continue reading

National Assembly passes three amendments to strengthen international tax compliance

BASSETERRE, St. Kitts -– The Government of St. Kitts and Nevis took steps on Friday, July 13, to further strengthen its proactive cooperation on tax matters through the passage of three amendments to the Common Reporting Standard (Automatic Exchange of Financial Account Information) (Amendment) Bill, 2018, in the National Assembly…. – Continue reading

FBR obtains information about Pakistanis’ immovable properties in UK

ISLAMABAD: Under a newly-signed agreement, Pakistan will have access to the information about its nationals’ assets abroad, it emerged on Monday. The Federal Board of Revenue (FBR) has obtained information regarding immovable properties owned by Pakistanis in the United Kingdom (UK). The information has been obtained with the assistance of… – Continue reading

Inland Revenue (Convention on Mutual Administrative Assistance in Tax Matters) Order gazetted and commences operation

Hong Kong (HKSAR) –      The Inland Revenue (Convention on Mutual Administrative Assistance in Tax Matters) Order (the Order) was gazetted and came into operation today (July 13). The Convention on Mutual Administrative Assistance in Tax Matters (the Convention) will enter into force in Hong Kong on September 1,… – Continue reading

Inland Revenue (Amendment) (No. 6) Ordinance 2018 gazetted

Hong Kong (HKSAR) – The Inland Revenue (Amendment) (No. 6) Ordinance 2018, which primarily implements the minimum standards of the Base Erosion and Profit Shifting (BEPS) package promulgated by the Organisation for Economic Co-operation and Development (OECD) and codifies the transfer pricing principles into the Inland Revenue Ordinance (Cap. 112)… – Continue reading

More Information… More Intense Transfer Pricing Disputes?

The Central Board of Direct Taxes has recently issued guidance on the appropriate use of the ‘Country-by-Country Report’. The CbC filing was introduced as a result of the OECD/G20 Base Erosion and Profit Shifting project. India also introduced the requirement to file CbC reporting recently with the completion of the… – Continue reading

United Arab Emirates: The UAE Tax Environment

The United Arab Emirates has more than 140 free zones across seven emirates, including 20 designated zones with separate laws, regulations and VAT treatment. This can make doing business in the UAE a complex journey. However, there is also the strong benefit of the UAE being one of the easier… – Continue reading

OECD Welcomes Dutch Efforts To Counter BEPS

The OECD has welcomed efforts by the Dutch Government to tackle base erosion and profit shifting but called for the overall tax regime to be simplified, including in area of value-added tax. In its latest Economic Report on the Netherlands, the OECD said that the Government is attempting to change… – Continue reading

Multinationals in New Zealand to pay fair share of tax

WELLINGTON, June 26 (Xinhua) — New measures to ensure multinational companies in New Zealand pay their fair share of tax will come into force next week. Revenue Minister Stuart Nash said the Taxation (Neutralizing Base Erosion and Profit Shifting) Bill, which passed its third reading in Parliament on Tuesday, takes… – Continue reading

OECD Releases First CbC Reporting Peer Reviews

The OECD has released the first peer reviews of the country-by-country (CbC) reporting initiative, reporting that practically all countries that serve as headquarters to large multinationals have introduced new transfer pricing documentation requirements to improve transparency. Country-by-country reporting will see tax administrations worldwide collect and share detailed information on all… – Continue reading

OECD backs BEPS plan in face of critics

The OECD has endorsed New Zealand’s crackdown on multi-national tax evasion, despite significant criticism from local businesses that it departs from OECD standards, Thomas Coughlan reports. David Bradbury, head of the OECD’s tax policy and statistics division, told Newsroom that the OECD was “very pleased with the strong support that… – Continue reading

‘Blacklist Over – But We Must Be Wary Of More Eu Pressure’

SENATOR Dion Foulkes yesterday forecast the country would soon face more pressures from the European Union and should be ready to act quickly to avoid further reputational damage. On Friday, Finance Minister K Peter Turnquest announced the Bahamas had been removed from the European Union’s “blacklist” of non-cooperative jurisdictions for… – Continue reading

Use Eu’s Demands To ‘Set Our Own Table’

The Bahamas must now focus on leveraging the European Union’s (EU) demands to “set our own table” and boost GDP growth and employment, a well-known attorney is urging. Michael Paton, also a former Bahamas Financial Services Board (BFSB) chairman, said this nation has the opportunity to design an “economic substance”… – Continue reading

Ownership Registry Is ‘Not Set In Stone’

Attorney General Carl Bethel QC. Photo: Terrel W Carey/Tribune Staff Legislation to create a central Beneficial Ownership Registry is “not set in stone”, the Attorney General has revealed, with the Government seeking “urgent” consultation on the issue. Carl Bethel QC, addressing a Bahamas Financial Services Board (BFSB)-sponsored seminar, said the… – Continue reading

$1.745m Software Deal To Facilitate Tax Exchange

The Ministry of Finance has embraced a software solution from Vizor AEOI Software to help meet its automatic tax information exchange (AEOI) commitments. The Bahamas will use Vizor’s solution to meet its obligations under the Organisation for Economic Co-Operation and Development (OECD)’s Common Reporting Standard (CRS), and its Foreign Account… – Continue reading

EU to remove two Caribbean countries from blacklist of tax havens

BRUSSELS, Germany (CMC) — Two Caribbean Community (CARICOM) countries are likely to be removed from the European Union list of tax havens next week, when European finance ministers meet here. The Bahamas and St Kitts-Nevis had in the past strongly objected to be included in the list put out by… – Continue reading