Multinational companies headquartered in Germany worry that when they report their global tax and profits for 2016, some countries will leak their country-by-country reports to the press. German parents of multinational groups with annual consolidated group revenue of at least 750 million euros ($797 million) are required to file, with… – Continue reading
THERE was a time when a tax professional would confidently tell you that tax avoidance would not get you in trouble. You might be bending the rules a little to minimise your tax liability, but as long as you followed the letter of the law, you would be fine. On… – Continue reading
Microsoft New Zealand is bracing for possible action from the taxman. The company said in its annual accounts that Inland Revenue was auditing payments charged to it by Microsoft companies overseas over the two years to June 2015. Microsoft NZ listed the Inland Revenue audit as a “contingent liability” for… – Continue reading
KUALA LUMPUR: The Inland Revenue Board (IRB) has its eye on tax evaders and tracking them down will be one of its priorities in 2017. IRB deputy chief executive Datuk Mohd Nizom Sairi said this is part of the agency’s plans to meet its target of RM127 billion in tax… – Continue reading
India has signed a bilateral advance pricing agreement with the Indian subsidiary of a Japanese company, India’s Central Board of Direct Taxes (CBDT) has announced. The APA was signed on January 13. With this, India and Japan have concluded three bilateral APAs, all of which include roll-back provisions. Overall, the… – Continue reading
India is unlikely to amend its tax treaty with the Netherlands as it did with Mauritius, Singapore and Cyprus and this could shape the investment strategy of foreign portfolio investors (FPI) and private equity (PE) funds investing in India, said three people in the know. “There were talks to amend… – Continue reading
The Slovak Government and Parliament made several changes to the tax system with effect from 1 January 2017. The recently adopted amendments concern – among others – corporate and personal income tax, value added tax, special levy in regulated industries, as well as social security and health insurance contributions. Here… – Continue reading
Move could be a worrying indicator of investment trends post-Brexit, post-Beps Snap, the company behind Snapchat, has opted to open its new new international headquarters in London, rather than Dublin, Amsterdam or Luxembourg, bucking a trend which for decades has seen US multinationals book their international sales in one of… – Continue reading
A plan by Nordea Bank AB to merge with subsidiaries in Denmark, Finland and Norway has prompted Sweden to revise its laws to minimize the risk of a tax imbalance when a foreign company’s shares and other financial instruments are merged with those of domestic company. Effective Jan. 1, the… – Continue reading
Authored by IFC Media Recent global events from the release of the Panama Papers to a series of high-profile inversions have given international tax regulators both rhetorical ammunition and public support to execute a global crackdown on multinational tax planning. The goal is to increase total taxes paid by global… – Continue reading
Hong Kong’s Financial Services Development Council (FSDC) has issued a paper setting out key recommendations for the Government to consider in the area of international tax law. The paper, which was issued on December 29, 2016, recommends that the Government should issue clearer guidance on appropriate transfer pricing methodologies for… – Continue reading
On 23 November 2016, the Swiss Federal Council adopted the dispatch on the Multilateral Agreement on the exchange of Country-by-Country Reports (CbCRs) and draft federal implementing legislation. The proposal is aimed at implementing the minimum standard of the G20 countries and the OECD to combat base erosion and profit shifting… – Continue reading
Starting April 1, 2017, India will have the right to tax capital gains arising on Indian equity shares sold by a Singapore resident. The governments of India and Singapore have amended the double taxation avoidance treaty between the two countries, in line with the changes India recently made to a… – Continue reading
On 8 December 2016 the Ukrainian Parliament adopted in its first reading the Draft Law No. 5368 “On Amendments to the Tax Code of Ukraine (regarding improving the investment climate in Ukraine)” (hereinafter the “Tax Reform Law”). The Tax Reform Law will introduce among other things changes to VAT administration,… – Continue reading
Tax directors and CFOs at multinational companies are facing increasing numbers of tax audits, and are becoming concerned about the impact of public perception of their tax planning on their company’s reputation, according to research by Taxand. Its fifth annual global survey of CFOs, tax and finance directors across Europe,… – Continue reading
Cyprus has been formally removed from India’s tax blacklist and will now not be considered as ‘non-cooperative’ jurisdiction for income tax purposes. The Central Board of Direct Taxes (CBDT) has issued a notification, rescinding it’s executive order blacklisting the island nation from November 1, 2013. Cyprus, a popular tax haven,… – Continue reading
Azerbaijan’s Taxes Minister Fazil Mammadov announced that operations with offshore companies are planned to be a subject of taxation in the country. Mammadov spoke about the changes to the Tax Code in a meeting of Azerbaijan’s parliamentary committee on economic affairs, industry and entrepreneurship. In tote, some 201 amendments and… – Continue reading
The Government is planning unilateral action to crack down on tax dodging by multinational companies, including changing the law, amid growing concern about fairness. Revenue Minister Michael Woodhouse said proposals outlined in a cabinet discussion document tabled last month would see Inland Revenue properly armed to tackle the problem and… – Continue reading
Lower corporate tax rates around the world are expected to play an important part in multinational companies’ tax planning in 2017, with a rate as low as 15 percent on the table in the U.S. and countries such as the U.K. planning to maintain or lower their current rates. A… – Continue reading
A showdown between the Australian Taxation Office and the nation’s largest companies including Chevron, Crown and BHP Billiton is looming as the tax man hits seven large companies with tax bills amounting to $2 billion. On Friday, the ATO released its corporate tax transparency report for 2014-15, which includes limited… – Continue reading
NEW DELHI: India and the US have reached a deal for the first bilateral advance pricing agreement, a move that will enable American firms to ascertain tax liabilities beforehand, Finance Minister Arun Jaitley said today. The two nations have resolved over 100 cases of tax disputes involving a tax of… – Continue reading
After recent scandals, many financial and wealth management centres are losing their allure and ‘mid-shore’ options are taking their place, argues Philip Marcovici. Will all existing financial and wealth management centres survive? Are tax-free secrecy havens (the “offshore world”) a feature of the past? Is there room for entry of… – Continue reading
Controversy over giant corporations paying dwarfed tax bills has put finance chiefs in the media and public spotlight When giant companies with devilishly complex tax arrangements are accused of unethical behaviour, the stock response is “we act within the rules”. If the public and politicians don’t like it, the argument… – Continue reading
The International Chamber of Commerce (ICC) welcomes the Organisation for Economic Co-operation and Development’s (OECD)’s release last week of a multilateral convention which allows for swift implementation of a series of tax treaty measures encompassed in the OECD/G20 Base Erosion and Profit Shifting (BEPS) project. The release follows the conclusion… – Continue reading
The amount of tax potentially underpaid by big businesses by shifting profits to other jurisdictions has increased by 60 percent in the last year, to GBP3.8bn (USD4.8bn), according to figures obtained by international law firm Pinsent Masons. The figure is the “tax under consideration” by HMRC’s Large Business Directorate, being… – Continue reading
The Kenya Revenue Authority has signed an international memorandum of understanding on tax collaboration with Botswana, to provide administration assistance from next year. Tax officials from Kenya and Botswana on Thursday agreed to the assistance project that marks the first South-South cooperation pact under the Tax Inspectors Without Borders programme… – Continue reading
On November 22, 2016, the Minister of Finance of Ukraine handed an official letter on Ukraine’s accession to the BEPS (Base Erosion and Profit Shifting) plan to the Secretary-General of OECD. Being the final stage in the process of joining the project, Ukraine is to become a member of the… – Continue reading
Big U.S. internet companies in France could get hit by a new BEPS-inspired penalty on “diverted profits” under a so-called Google tax measure that France’s National Assembly is set to consider next week. The amendment, proposed by Socialist Deputy Yann Galut and adopted by the Assembly’s finance committee, targets foreign… – Continue reading
SEOUL, Nov. 17 (Yonhap) — U.S. President-elect Donald Trump’s pledge for a huge corporate tax cut could spur moves to reduce taxes on businesses and the rich across the world, a Seoul-based think tank said Thursday. During the campaign, the real estate mogul-turned-politician vowed to lower the business tax rate… – Continue reading
Just a handful of dodgy tax structures being used by Australians cost tens of millions of dollars in lost revenue, according to the Australian Taxation Office. That could mean many millions more are missing, and is why the ATO is cracking down on people misusing trusts. The agency has long… – Continue reading
Nov. 15 — The German Cabinet is preparing to address a bill Dec. 21 to combat tax evasion by cracking down on letterbox companies and banking secrecy as a response to the Panama Papers and other scandals involving sophisticated forms of tax planning. The bill, prepared by the Federal Ministry… – Continue reading
Adoption of legislation for a common consolidated corporate tax base by 27 EU member states would resolve current patent box conflicts and end transfer pricing disputes that cost multinational companies hundreds of millions of dollars in double taxation, according to EU and industry officials. Speaking at a Nov. 15 conference… – Continue reading
Background The Federal Inland Revenue Service [FIRS] has begun Transfer Pricing [TP] audits and has been requesting TP documentation and other documents from taxpayers relating to their related party transactions. These actions are in line with its powers under the Income Tax (Transfer Pricing) Regulations No. 1 of 2012 [Regulations]… – Continue reading
With Republican control of the House and Senate, President-elect Trump and Congress might tell the tax code, “you’re fired!” And as big as the coming tax changes might be, it’s worth noting what is highly unlikely to change. Keeping track of these 13 key tax rules could put dollars in… – Continue reading
MUMBAI: With a hope of improving India’s image on ease of doing business, the government has increased the pace of resolving transfer pricing issues and is looking to sign around 100 advance pricing agreements by the end of March 2017, people in the know said. Central Board of Direct Taxes… – Continue reading
The European Commission has launched a public consultation on how best to deter promoters of aggressive tax planning schemes. The Commission said it is particularly interested in gathering views on how a mandatory disclosure scheme for tax advisers could be put in place. If implemented, this would require intermediaries to… – Continue reading
While Trump wants to close loopholes, many of them stem from public policy concerns — not “special interests.” After a dramatic upset victory in one of the most bitterly contested presidential races in recent history, Donald Trump now has some serious work to do. His corporate tax policies—which are vital… – Continue reading
New Zealand’s tax agency has set out the international tax initiatives it intends to pursue, in particular in response to the OECD’s base erosion and profit shifting plan. It said it will undertake further work on a package of BEPS initiatives, which will include hybrid mismatch rules to prevent companies… – Continue reading
Ninety-eight countries are poised to formally adopt the OECD’s innovative multilateral tax treaty, which will place recommendations from the BEPS project into more than 3,000 bilateral accords, when the ad-hoc group meets later this month. The “Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting”… – Continue reading
A multinational company based in a jurisdiction that has no tax treaty with Israel must pay Israeli taxes on its Israel-related earnings from international money transfer services, the Israel Tax Authority determined. The ruling is set to apply to the growing number of financial service firms entering the Israeli market,… – Continue reading
Vietnam’s Ministry of Finance released a draft circular on October 11th which, if passed, is set to become the largest change to transfer pricing (TP) regulation since the implementation of Circular 66/2010/TT-BTC in 2010 – which the draft updates. Touching on conditionality of TP exemption and thresholds for defining related… – Continue reading
Many kinds of U.S. multinational companies, including S-corporations, REITS, and financial services companies apparently dodged a bullet last month when the U.S. Treasury Dept. issued its final, substantially revised rules aimed at curtailing “earnings stripping.” The revised regulation represents an attempt by Treasury to help “narrow the rule and avoid… – Continue reading
The Internal Revenue Service lacks a strong operation to audit a critical international tax compliance area, according to a watchdog report released Thursday. At issue is transfer pricing, a cost structure used by multinational companies to price goods and services they sell to subsidiaries in foreign locations. The IRS requires… – Continue reading
On November 3, 2016, the Inland Revenue Authority of Singapore (IRAS) released details of a new form that certain companies will be required to file from the 2018 assessment year to report their related-party transactions. The form must be completed and filed together with the income tax return (Form C)… – Continue reading
Global governments battling tax avoidance increasingly are pushing multinational corporations for a bigger picture of how and where they pay taxes, leading to increasingly narrow questions from company tax officers. “We have a number of entities that are disregarded for U.S. tax purposes. When I fill out the country-by-country form,… – Continue reading
The leading UK accountancy and tax bodies in the UK have released updated guidance on the standards expected of tax advisers and agents. The seven organizations – the Chartered Institute of Taxation, the Association of Taxation Technicians, the Association of Accounting Technicians, the Association of Chartered Certified Accountants, the Institute… – Continue reading
Historically, the Middle East and North Africa (MENA) region has been perceived as a region where taxation and transfer pricing initiatives are not high up on government agendas. Although this has been the case for a significant period of time, recent changes in the region such as decreases in global… – Continue reading
The OECD has started to review how effectively the U.S. and five other countries handle cases in which multinational companies assert double taxation under the mutual agreement procedure of bilateral tax treaties. As part of the review, the Organization for Economic Cooperation and Development is inviting multinationals to answer a… – Continue reading
The British arm of McDonald’s paid £123m for “franchise rights” last year, as part of a controversial structure that is under investigation for enabling unfair tax avoidance. The European Commission launched a probe last year into whether Luxembourg’s tax arrangements for McDonald’s amounted to illegal state aid, as part of… – Continue reading
The APA scheme was initiated in 2012 in the IT Act and in 2014, rollback provisions were introduced. The Dollar Business Bureau The Central Board of Direct Taxes (CBDT) on Thursday signed five Unilateral Advance Pricing Agreements (APAs) with Indian taxpayers, making the total number of APAs to 108. “The… – Continue reading
