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
On September 17, 2019, the Dutch government released the Budget 2020 containing its Tax Plan 2020 with certain amendments to Dutch tax law. ... - Continue reading
Initial results of a study conducted by the Bangko Sentral ng Pilipinas show that an immediate pullout by Philippine offshore gaming operators from the country will not have an impact on the financial stability, Governor Benjamin Diokno said Tuesday. Diokno asked the BSP’s Financial Stability team and the Anti-Money Laundering… – Continue reading
The Dutch tax authorities have issued British American Tobacco with a €1bn bill for back taxes after a tax evasion investigation, website De Onderzoeksredactie has reported. ... - Continue reading
KARACHI: Foreign portfolio investors invested $143.633 million in treasury bills from July onwards as the present government started betting on overseas funds into debt securities to finance budget deficit and refinance maturities. The State Bank of Pakistan’s (SBP) latest data showed that outflow from portfolio investors amounted to $5.808 million… – 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
From April 2019, all direct disposals of UK land and property by non-UK residents are now subject to UK tax on capital gains ... - 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
A gold trader has been acquitted by the Court of Tax Appeals in the P110-million tax evasion case for the failure of the Bureau of Internal Revenue (BIR) to prove his guilt beyond reasonable doubt.n a 56-page decision, the CTA’s Second Decision said the BIR was not able to present… – 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
The start of a new European Commission also means setting new political priorities in the EU tax field. ... - Continue reading
Senator Joel Villanueva has urged the Department of Interior and Local Government (DILG) to order local government units and police to crack down on Philippine offshore gaming operations (POGOs) that refuse to comply with the country’s tax laws. Villanueva also backed the Department of Finance’s (DOF) order to shut down… – 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
'Those who don't pay or respond to your assessments, clamp them down,' says Finance Secretary Carlos Dominguez III ... - 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
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
Colombia's National Directorate of Taxes and Customs (DIAN) released detailed guidelines (the Guidelines) to clarify the procedure for Advanced Transfer Pricing Agreements (APAs) requests in order to ensure certainty between the parties regarding their transfer pricing arrangements. ... - Continue reading
Multinational companies channel more than $3 trillion a year in “phantom” foreign investment through the Netherlands in order to bring down their corporate tax bills, according to research published in the Financial Times. ... - Continue reading
The Cabinet of Ministers has approved a bill to ratify the Agreement between the governments of Ukraine and the United States to improve tax compliance and application of provisions of the U.S. Foreign Account Tax Compliance Act (FATCA) and related bills, the Ukrainian Finance Ministry’s press service reported. “On September… – 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
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
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
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
FINANCE Secretary Carlos Dominguez 3rd is pushing for tax perks to be reviewed every two years as he reiterated that the Philippines had been too generous in granting incentives to select companies. In a statement on Thursday, the Department of Finance (DoF) quoted its chief as saying the government must… – Continue reading
ISLAMABAD: The Economic Coordination Committee (ECC) of the cabinet on Wednesday approved a new tax regime for non-resident companies to attract investment into the local debt market, while it also directed officials to check wheat price hike in Karachi and other parts of the country. The ECC approved the tax… – Continue reading
The Cyprus Investment Programme is rapidly becoming one of the EU’s most popular residence schemes.
Transfer pricing disputes in Canada have, predominately, been resolved through either a request for competent authority assistance under the Mutual Agreement Procedure ("MAP") of a treaty, or, to a much lesser extent, through the notice of objection process with CRA Appeals. Regardless of the recent increase in transfer pricing cases being brought before the Courts, the MAP will likely continue to be the dispute resolution process most often utilized by a Canadian corporation in transfer pricing cases because, in the absence of a 100% reversal of a transfer pricing adjustment by either CRA Appeals or a Canadian court, economic double taxation may still exist as a consequence of the CRA upward transfer pricing adjustment. The correlative relief provided by the treaty partner under a MAP settlement resolves that double taxation. ... - 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
The Australian Tax Office on 28 August, released its awaited draft guidance contained in Practical Compliance Guideline 2019/D3, on applying the arm’s length debt test contained in Division 820 of the Income Tax Assessment Act 1997, Australia’s thin capitalization statutory provisions. ... - 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
ISLAMABAD: The Federal Board of Revenue (FBR) has served a notice on ARY Communications Limited (ARY) and raised a tax demand of Rs992 million – alleging that the entity had evaded tens of millions in taxes through misrepresentation, concealment and misuse of exemptions, thereby causing a substantial loss to the… – 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
The taxman is raking in record amounts in income tax as the latest figures reveal Britons paid an extra £11bn in 2018/19. Income tax receipts have soared to a record £191bn, according to figures published, a 6% increase from the previous year. Britons are paying almost 30% more income tax… – 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
