Category: Activity

Draft Bulgarian tax law reflects EU legislation on mandatory automatic exchange of tax information

At the end of March 2017, the Ministry of Finance called for public discussion on a draft bill (the “Bill”) amending the Bulgarian Tax and Social Insurance Procedural Code (the “Code”). The Bill seeks to improve administrative cooperation in the Bulgarian tax sector. The first set of amendments relates to… – Continue reading

10 ways you stand to gain from filing income tax return

Filing of your income tax return (ITR) is mandatory under the Income Tax Act, 1961 under certain circumstances. For instance, if someone’s income exceeds the maximum amount not chargeable to tax, one is required to file income tax return.  Similarly, filing ITR is mandatory for ordinary residents having overseas assets… – Continue reading

Understanding the taxation of international and expatriate assignments

(Second of two parts) In last week’s article, we discussed how or why taxpayers working on international assignments have to consider the impact of different tax jurisdictions on their individual tax obligations. We also explained how most companies implement a tax equalization (TEQ) arrangement for the employees so that they… – Continue reading

OECD Holds Global Forum On VAT

Approximately 300 participants, representing over 100 delegations from countries, jurisdictions, and international organizations gathered in Paris for the fourth meeting of the OECD Global Forum on VAT on April 12-14, 2017. The keynote address was delivered by Wang Jun, China’s Minister of Taxation, who discussed the implementation of value-added tax… – Continue reading

Tax amnesty plan premature, says Citi

MANILA, Philippines – Instead, the government should pursue the enactment of the proposed Comprehensive Tax Reform Program (CTRP) before pursuing a tax amnesty program, Citi economist Jun Trinidad said. He said fiscal priority remains the passage of the first component of the tax reform measure that includes income tax cut… – Continue reading

Tax amnesty plan faces hurdles – Credit Suisse

MANILA, Philippines – Investment bank Credit Suisse said an effective tax amnesty program would face hurdles in the Philippines due to the country’s strict banking secrecy law. In its Asian daily report titled “Philippines: Credible threat still lacking,” Credit Suisse economist Michael Wan said the planned program announced by Finance… – Continue reading

Germany Provides Update On 10-Point Tax Evasion Plan

The German Ministry of Finance has published a progress report on its 10-point plan to combat tax evasion, which was first announced in the wake of last year’s Panama Papers leak. The plan, launched on April 12, 2016, outlines the measures that Germany wants to put in place at domestic… – Continue reading

Sweden Considers New Reporting Obligation for Tax Advisers

A parliamentary commission will consider the introduction of a new legal obligation for tax advisers to disclose information about advice on tax mitigation to the Swedish Tax Agency, Skatteverket. Under the proposed rules, tax attorneys would be required to provide details of which clients have received advice on tax reduction… – Continue reading

OECD’s BEPS 13 implemented in Croatia

With a total of 15 action points, the OECD’s Base Erosion and Profit Shifting (BEPS) project aims at fighting the artificial shift of profits from jurisdictions with high taxes to tax havens, often as a part of an entirely legal strategy used by MNEs. The BEPS Action 13 (Transfer Pricing… – Continue reading

Cyprus: Abolition Of Profit Margins On Intra Group Loans – Upcoming Transfer Pricing Legislation – Transfer Pricing Studies Requirement

As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length… – Continue reading

Withholding tax on dividends – A bagful of uncertainties and complexities?

Muscat: One of the many changes that the Royal Decree 9 of 2017 (RD) has made in the Oman Income tax law is the introduction of withholding tax (WHT) on payment of ‘dividends on shares’ by Omani companies. This amendment requires Omani companies distributing dividends on shares to foreign persons… – Continue reading

Tax evasion of more than Rs 1.37 lakh crore detected in last three years

The Revenue Department on Friday said it has detected evasion of more than Rs 1.37 lakh crore in both direct and indirect taxes and identified over 1,000 shell companies which indulged in bogus transactions worth Rs 13,300 crore in the last three financial years. Warning tax evaders, it said the… – Continue reading

How to Shut Down Offshore Corporate Tax Avoidance, Full Stop

A new bill introduced this week by Rep. Mark Pocan (D-WI), the Tax Fairness and Transparency Act, would rip out the offshore corporate tax avoidance system by its roots. This legislation combines into a single, comprehensive bill elements of three pieces of legislation that Rep. Pocan has proposed in previous… – Continue reading

Corporate giants hit with $2.2b Australia tax bill

Companies including Apple, Google and BHP Billiton were grilled at parliamentary hearings on their tax structures in 2015 SYDNEY: Australia on Thursday said it had slapped seven large multinationals with a multi-billion-dollar tax bill as it pursued global firms shifting profits offshore to minimise liabilities. The companies hit with the… – Continue reading

China’s New Transfer Pricing Rules Keep Arm’s-Length Approach

China’s new transfer pricing rules, effective May 1, endorse the continued use of the arm’s-length standard—the internationally agreed bedrock for pricing transactions within multinational enterprises. The new guidance, Bulletin 6, augurs well for resolving tax disputes between China’s State Administration of Taxation and the U.S. Internal Revenue Service over the… – Continue reading

G20 Citizens Favor BEPS Crackdown Over Tax Competition

Citizens in G20 countries would prefer their government engage in international efforts to improve the functioning of international tax rules than compete for tax receipts, says a new survey. G20 public trust in tax, a report compiled by the ACCA (the Association of Chartered Certified Accountants), IFAC (the International Federation… – Continue reading

Deloitte Middle East Point of View: Ethical tax, construction market outlook, ISO 37001 on anti-bribery management, and GCC family businesses

Financial institutions are working together to combat tax evasion, bribery and corruption through ISO certifications and the Common Reporting Standard. These are among the topics discussed in the spring 2017 issue of Deloitte’s quarterly publication, the Middle East Point of View (ME PoV). The spring 2017 issue tackles several hot… – Continue reading

Time to tackle the shell companies

Hyderabad: Shell companies are becoming a common phenomenon globally and even in India. These companies are posing several challenges to governments and regulators for various reasons had been probing their involvement in large scale money laundering and tax avoidance cases. A shell company is a non-trading organisation that does not… – Continue reading

OECD recommends introduction of US-style deferred prosecution agreements in Scotland

ANALYSIS: US-style deferred prosecution agreements (DPAs) should be introduced in Scotland to deal with corporate offending, according to a recent report by the global Organisation for Economic Cooperation and Development (OECD). Foreign bribery should attract significant penalties, and Scotland’s civil settlement regime is potentially too lenient, according to the report,… – Continue reading

New Chinese tax rule to take aim at multinationals’ profit shifting

Move shows that Beijing is joining the global move against diversion of profits to low-tax jurisdictions Beijing on Saturday posted a new rule on scenarios that could trigger tax-avoidance investigations of multinationals, under¬lining its commitment to a global move to combat profit shifting. The new rule, posted on the website… – Continue reading

Singapore is Proven to be Indonesians’ Tax Haven

Singapore is home to the majority of the Rp 1,174-trillion assets overseas owned by Indonesians, which had been declared and repatriated to Indonesia under the Tax Amnesty program. Indonesia, – Indonesia’s tax amnesty program has proven public claim that Singapore is a favorable place for wealthy Indonesians to store… – Continue reading

Chile Leads Region to Test Companies’ International Tax Links

Chile is leading a regional push across Latin America to clamp down on tax avoidance and profit-shifting by multinational and local firms, with the country’s tax authority making companies with interests and assets one of its priorities for inspections this year. Outlining its tax enforcement plan for 2017 on March… – Continue reading

1099 Pro Offers Common Reporting Standard Software for CRS Reporting

1099 Pro now offers Common Reporting Standard software for CRS reporting as part of the OECD’s Automatic Exchange of Information for Tax Matters (AEoI) program. 1099 Pro, Inc.,, known for over 25 years of Windows based product development for 1042-S, 1099, & FATCA reporting recently confirmed the upcoming release… – Continue reading

[News Focus] Multinational firms using royalties to avoid tax: expert

Multinational firms in South Korea tend to transfer much higher proportions of their revenues to their headquarters overseas in dividends and royalties than their Korean counterparts, an expert said Monday. Payments in royalties and dividends are categorized as expenses, which in turn lowers their reported earnings to the Korean authorities…. – Continue reading

Brazil’s Petrobras Loses Appeal of Double Taxation

For the second time in 14 months, Brazil’s state oil company Petrobras has lost a dispute over Brazil’s recognition of tax treaties. On March 24, a federal revenue service appeals court ruled against Petrobras in a $510 million case (16682.721067/2014-01) involving the company’s profits in the Netherlands for 2010. Although… – Continue reading

Focus BEPS Work on Practical Results, Not Participation: Stack

The OECD effort to rebuild the global tax system should focus on practical work that benefits the international tax community rather than trying to get as many countries as possible around the table, a former Treasury official said. The OECD’s so-called inclusive framework for implementing the four minimum standards of… – Continue reading

Art of the deal: Trump, Dems look for common ground to close tax loopholes

Venture capitalists, investors left unfazed Both President Trump and Capitol Hill Democrats head into negotiations over tax reform vowing to put the squeeze on hedge fund managers by closing the carried interest tax loophole — a point of agreement that held out promise for becoming a foundation for a once-in-a-generation… – Continue reading

BEPS from an IP perspective, Part 2

Part 2: Transfer Pricing documentation requirements From 1 April 2017, BEPS action 13 guidelines on transfer pricing (TP) documentation will be effective in Sweden. Action 13 is an effort to make MNEs global financial situation more transparent. It is a three-tiered based approach including a master file, local files and… – Continue reading

Slovakia Urged To Redouble Efforts Against Tax Evasion

Slovakia should tackle value-added tax and corporate tax evasion, the International Monetary Fund has said. In its annual report for the country, the Fund said that measures to target tax fraud and non-compliance have reduced the VAT gap – the amount lost compared with the theoretical maximum were the headline… – Continue reading

Investors face higher tax bills on stapled securities

The federal government is considering doubling the tax rate applied to more than $199 billion worth of so-called stapled structures, in a move that experts say could scare off foreign investors. Separate securities, such as a share in a company and a unit in a trust, can be stapled together… – Continue reading

House bills to fund infrastructure reward big multinationals

U.S. Rep. John Delaney has introduced two infrastructure funding bills — H.R. 1669 and H.R. 1670 — that good government groups say would further incentivize corporate tax dodging, reward the biggest multinational corporations for stashing their profits in offshore tax havens and replace one system riddled with tax loopholes with… – Continue reading

Amazon not liable for $1.5bn tax bill, judge rules

Online giant wins transfer pricing case against US Internal Revenue Service Amazon. com has won a tax dispute with the US Internal Revenue Service (IRS), involving more than $1.5 billion (€1.39 billion), in relation to the transactions of a Luxembourg unit more than a decade ago. Judge Albert Lauber of… – Continue reading

Law Society reaches understanding with IRD on FATCA

The New Zealand Law Society says that following discussions with Inland Revenue and the New Zealand Bankers’ Association it has now reached an understanding with Inland Revenue about application of FATCA to lawyers’ trusts accounts. FATCA is the United States’ Foreign Account Tax Compliance Act. Its objective is to reduce… – Continue reading

UK To Expand Double Tax Treaty Passport Scheme

HM Revenue and Customs (HMRC) is planning to make its Double Taxation Treaty Passport (DTTP) scheme available to all UK borrowers following a consultation on a legislative amendment. The DTTP scheme provides for Double Taxation Relief on UK loan interest payments made by a UK corporate borrower to overseas corporate… – Continue reading

Countries ‘losing £400bn in taxes a year to profit shifting’

Governments around the world are losing as much as half a trillion US dollars (£400 billion) a year in tax revenue due to so-called “profit shifting” by multinational companies, according to research. The research published by the Tax Justice Network found that poorer countries were hardest-hit by the practice, which… – Continue reading

EU Lawmakers Visit IRS, Delaware as Tax Haven Concerns Mount

The European Parliament’s Panama Papers investigative committee is preparing for a “fact-finding” visit with counterparts in the U.S. Congress, as well as officials from the Treasury Department and Internal Revenue Service. The European Union lawmakers’ four-day U.S. trip, which begins March 21, will include a visit to Delaware for meetings… – Continue reading

Finance Bill confirms measures to crack down on tax avoidance

The 2017 Finance Bill was published on Monday 20 March, introducing dozens of initiatives with a focus on improving and modernising the tax system The Treasury said the bill, which is over 700 pages in length, “continues the government’s crackdown on tax avoidance” and “improves the fairness of the tax… – Continue reading

Facebook, Google paying more local tax in Australia after tax avoidance crackdown: officials

Multinational companies are now paying tax based on their Australian profits instead of shifting income to low-tax countries, officials say. CANBERRA, AUSTRALIA—Facebook, Google and other multinational companies are now paying tax in Australia based on their Australian profits instead of shifting income to low-tax countries since the government cracked down… – Continue reading

Treasurer to launch fresh attack on multinational tax avoidance as Parliament resumes

Treasurer Scott Morrison will launch a fresh attack on tax avoidance this week in Parliament in a bid to get the so-called “Google Tax” pushed through and shift public attention towards the Coalition’s record on multinational tax crackdowns. The Diverted Profits Tax is due to be debated this week, almost… – Continue reading

OECD, IMF Reports On Providing Businesses With Tax Certainty

The OECD and the International Monetary Fund have submitted to the Group of Twenty (G-20) nations a report on improving tax certainty for businesses. The report follows a global survey of more than 700 large, multinational businesses and a survey of 25 advanced nation tax administrations. The report highlights several… – Continue reading

Recourse to MAP and bilateral APA rollback available under revised tax treaty: PwC

MUMBAI: The recent changes in the India and South Korea Agreement for Avoidance of Double Taxation provides recourse to taxpayers of both countries to apply for Mutual Agreement Procedure (MAP) in respect of transfer pricing disputes, and also to apply for bilateral Advance Pricing Agreements (APA) for APA period beginning… – Continue reading

Westpac crackdown on foreign buyers and money laundering

Property buyers will be quizzed about their tax residency under new anti-money-laundering rules being introduced by Westpac and its subsidiaries St George Bank, Bank of Melbourne and BankSA. Mortgage brokers, who act as intermediaries between the banks and buyers, are being told that from this week they must also ask… – Continue reading