After five years of negotiations, the European Commission has finally announced its plans to overhaul the way in which companies are taxed in the Single Market. The revised Common Consolidated Corporate Tax Base (CCCTB) is aimed at making it easier and cheaper to do business in the Single Market and… – Continue reading
On October 26, Hong Kong’s Government launched a public consultation on the implementation of base erosion and profit shifting (BEPS) measures proposed by the OECD. “Hong Kong is supportive of international efforts to promote tax transparency and combat tax evasion,” said Secretary for Financial Services and the Treasury K C… – Continue reading
India has notified the revised double tax avoidance agreement with South Korea under which capital gains tax will be levied at the source with effect from April 1, 2017. The existing Double Taxation Avoidance Convention, which has been in vogue for three decades, provides for residence-based taxation of capital gains… – Continue reading
A new EU corporate tax proposal could fundamentally change how multinationals pay their tax bills in Ireland. It comes at a sensitive time for the State, following so closely after the commission ruled phone giant Apple tapped illegal tax breaks worth around €13bn. In proposals to be unveiled tomorrow, the… – Continue reading
China is requiring multinational groups to provide more information, including the location-specific advantages of their Chinese entities, when they apply for advance pricing agreements. The State Administration of Taxation’s Public Notice 64, dated Oct. 11 and released Oct. 18, requires companies to provide the additional information to Chinese tax authorities… – Continue reading
One of the most common ways multinationals take advantage of current laws to reduce their tax bill is through what’s known as transfer pricing. Former Treasurer Wayne Swan last week accused mining giant BHP of “aggressive transfer pricing,” denying the Australian government A$5.7 billion in tax revenue. For most companies,… – Continue reading
U.S. companies operating contract manufacturers in Mexico can avoid double taxation between the United States and Mexico under a deal struck between their respective tax authorities and unveiled Friday by the IRS. So-called maquiladoras can avoid double taxation through a unilateral advance pricing agreement signed with the Servicio de Administración… – Continue reading
Applicable to transfer pricing for MNCs whose consolidated annual revenue is over Rs 5,000 crore The finance ministry will issue rules and guidance to address some concerns and ambiguity over mandatory reporting norms with respect to transfer pricing for multinational companies whose consolidated annual revenue is over Rs 5,000 crore…. – Continue reading
Former Labor treasurer Wayne Swan has accused one of Australia’s biggest companies of evading taxes for more than a decade, and for lying to the former Labor government during the height of the mining tax debate. Swan used parliamentary privilege on Wednesday to claim BHP Billiton had been “gaming the… – Continue reading
European Union plans to regulate tax advisers in an effort to clamp down on aggressive tax planning and tax avoidance could prove excessive, ineffective and trigger unfair competition, accountants and lawyers warn. The caution comes after EU finance ministers moved Oct. 11 to authorize the European Commission to draw up… – Continue reading
Tough rules to regulate tax advisers, banks and lawyers who help companies avoid tax are set to be advanced by European Union finance ministers. The Council of Economic and Financial Affairs Oct. 11 also will likely move toward a system of automatic exchange of beneficial ownership registers to better target… – Continue reading
The Inland Revenue Authority of Singapore (IRAS) has published detailed guidance on the implementation of a new country-by-country (CbC) reporting requirement in the territory. The guidance, released on October 10, sets out which entities are obliged to report and how to complete and submit a CbC report to IRAS. For… – Continue reading
EY announced today the results of a new tax survey at its 35th Annual International Tax Conference, “Unlocking the future.” The survey revealed that, more than ever, companies are experiencing an increasing number of audits and more aggressive enforcement from tax authorities around the world. According to the survey, nearly… – Continue reading
Various agencies are expected to work together to draft a decree and keep the practice in check. In a move that signals Vietnam’s apparent stronger stance against tax evasion, the Ministry of Finance has sought to work with other ministries and agencies to draft a new decree on transfer pricing… – Continue reading
Ethiopia recently adopted new transfer pricing rules in the form of Directive 43/2015 (“the Directive”) issued by the Ministry of Finance and Economic Development. The Directive provides detailed guidance as to the application of Article 29 of the Income Tax Proclamation (ITP) 286/2002, which requires taxpayers to ensure transactions between… – Continue reading
The Indonesian government recently launched tax hunt on Google Indonesia. If Google were indeed guilty of tax avoidance, it would have to pay a huge price for its actions. But Google is not alone in avoiding paying tax to Indonesian government. Indonesians and Indonesian companies are squirrelling their wealths in… – Continue reading
Ireland, accused of being a tax haven for multinationals such as Apple to pay nearly zero tax on the bulk of its profits earned outside the United States, finds itself with a new adversary in the global fight against unfair tax practices — Brazil. As of October 1, Brazil will… – Continue reading
Around 35 per cent of businesses in India have changed their tax approach following the OECD Base Erosion and Profit Shifting (BEPS) tax plan, higher than the global average, says a report. The Grant Thorntons recently conducted global survey of 2,600 businesses in 36 countries, found little impact of the… – Continue reading
A multi-billion euro back tax bill handed to Apple by the European Commission should not be seen as a precedent for future tax cases as it was based on state aid rather than tax law, the OECD official spearheading global tax reform said on Monday. European Union antitrust regulators last… – Continue reading
The threshold could be R5,400 crore of annual consolidated group revenue for the purpose of country-by-country reporting Not more than 120 India-headquartered firms — along with their global associates — are likely to be impacted by the base erosion and profit shifting (BEPS) protocol once it is implemented, as the… – Continue reading
India’s advance pricing agreements (APAs) programme crossed a milestone with the Central Board of Direct Taxes (CBDT) signing five more unilateral APAs. With the latest move, the total number of APAs entered into by the CBDT has reached 103. The five APAs signed on Friday pertained to diverse sector, that… – Continue reading
House Democrats have introduced legislation that would require multinational corporations to disclose more information about the taxes they pay in other countries. The bill, known as the Corporate Transparency and Accountability Act, aims to shine more light on corporate tax avoidance strategies, requiring the disclosure of country-by-country and pre-tax profit… – Continue reading
Nearly a year after release of the OECD Base Erosion and Profit Shifting (BEPS) anti tax avoidance action plan, which introduces changes to the treatment of interest deductibility and profit shifting, the majority of businesses have not changed their approach to tax compliance. The major economies in the G7 (83%),… – Continue reading
Auditing and tax advisory firm KPMG is calling for establishment of the T&T Revenue Authority (TTRA) so there can be a structured way of collecting taxes. “The current main tax authority does not appear to have structured means, if any, of treating with businesses that conceal transaction to avoid tax… – Continue reading
China’s State Administration of Taxation (SAT) issued the Announcement on the Administration of Related-party Transactions and Contemporaneous Documentation (SAT Announcement [2016] No. 42), which introduces a three-tiered documentation framework that will replace its current transfer pricing documentation rules. The June 29 announcement followed the publication of the opinion-seeking draft by… – Continue reading
Back in July, ABC’s The Business and Michael West featured an extraordinary raft of allegations from a 32-year veteran industry insider turned whistleblower, George Rozvany, who claimed that multinational tax avoidance was “out of control” and cost the Budget up to $50 billion dollars a year in lost revenue. Rozvany… – Continue reading
OECD Secretary General Angel Gurría has stressed the need for policy makers to provide a certain tax environment for businesses, to maintain trade and investment. Discussing the tax challenges facing EU countries at the informal meeting of EU finance ministers, held in Bratislava, Slovakia, on September 10, 2016, Gurría said:… – Continue reading
Apple Inc. may face double taxation on some of its profits if the European Commission’s Aug. 30 ruling inspires France to slap its own tax adjustment on the company, practitioners said. Apple could even face “triple taxation” if it repatriates profits from the European Union to the U.S., Laurent Leclercq,… – Continue reading
Slovakia, the current president of the EU council, challenges finance ministers from all the EU member states to introduce mandatory disclosure rules for intermediaries including accountants who seek to profit from the promotion, design or implementation of tax avoidance schemes The proposals were outlined in a ‘presidency issues’ note presented… – Continue reading
A recent 2016 tax reform in Japan (“Reform”) has introduced stringent Japanese Transfer Pricing Documentation Requirements, which require the preparation/filing of: (i) a Master File, (ii) a Country-by-Country Report, and (iii) a Local File, as well as (iv) a “Notification of the Ultimate Parent Entity.” Any ultimate parent company (“Parent… – Continue reading
The international tax landscape has been changing rapidly and the Organisation for Economic Co-operation and Development (OECD) has agreed on a base erosion and profit shifting (Beps) action plan that could affect businesses operating in the UAE. The plan addresses the issue of artificial shifting of profits and its proposals… – Continue reading
Today, we see more enthusiasm for tax reform in Indonesia. Although opposed by some civil society groups, President Joko “Jokowi” Widodo’s administration continues to push its fiscal framework reform — which includes a tax amnesty and more incentives for taxpayers. Last year, the Finance Ministry issued a new tax holiday… – Continue reading
Recent developments in the global business environment which are characterized by intense competition and rapid growth of multinational enterprises have led to new business models and structuring of business operations in order to meet the increasing demands of expansion on a global scale. Agency arrangements, as a way for enterprises… – Continue reading
The Central Board of Direct Taxes (CBDT) entered into twenty (20) Unilateral Advance Pricing Agreements (APAs) with Indian taxpayers. Many of these agreements also have a “Rollback” provision in them, Ministry of Finance said. The 20 APAs signed in these two days pertain to various sectors of the economy like… – Continue reading
Disclosures under the MAP are aimed at improving dispute resolution mechanism and are part of global initiative on base erosion and profit shifting. India will soon disclose the number of disputes being negotiated under the mutual agreement procedures (MAP) of tax treaties as well as details of the time being… – Continue reading
For the last three years, the international debate on tax policy was all about consensus. Led by the Organisation for Economic Co-operation and Development, countries across the globe agreed that aggressive tax planning by multinational corporations which pushed profits into low-tax countries – or indeed took profits outside the charge… – Continue reading
Under EU rules it is illegal for countries to give financial help to some companies and not others in a way that distorts fair competition, writes Liza Lovdahl Gormsen. State aid rules were originally designed to protect the internal EU market and avoid retaliation among member states. The US Treasury,… – Continue reading
The US has warned the EU that it risks damaging international agreements on tax reform if it continues to act as a “supra-national tax authority”. The US Treasury Department “shares the European Commission’s concern with tax avoidance by multinational firms. The international community, including the EU and its member states,… – Continue reading
Regulators in Europe and the US say that the value Amazon places on the technology behind user experience varies radically depending on which appraisal will lower its tax bill. Jeff Bezos’s relentless focus on user experience has helped him make Amazon the most valuable e-commerce company in the world. But… – Continue reading
THE OECD/G-20 Base Erosion and Profit Shifting (BEPS) Project is designed to provide solutions for governments to close the gaps in existing international rules that allow corporate profits to “disappear” or be artificially shifted to low or no tax environments, where companies have little or no economic activity. In February… – Continue reading
The U.K. government has been consulting on a proposed “Interest Restriction” rule which will limit the amount of interest expense U.K. companies will be allowed to offset against their income for tax purposes (to 30% of their taxable earnings before interest, tax and amortization). The second consultation phase on the… – Continue reading
Democrats are likely to object to the House GOP’s and Donald Trump’s plans for sharply lower rates President Ronald Reagan once chided government’s approach to the economy as following this mantra: “If it moves, tax it.” Today’s Republicans are following Mr. Reagan’s ideas by trying the exact opposite approach. The… – Continue reading
An IRS official said the agency is continuing its work on a mechanism to allow voluntary filings of country-by-country reports for companies required to comply with both the U.S. rules and those in a foreign country with an earlier effective date. “Actually being able to accept CBC reports for the… – Continue reading
Apple is a major part of why the United States is the world’s leading innovator on new technologies, particularly those involving telecommunications and computers. The company has over 66,000 domestic employees, and a large percentage of its customers are here — at least 40 percent, according to its latest annual… – Continue reading
On June 7, AEI hosted two panels on how the US could reform the corporate tax code, the first focusing on business-level taxation and the second focusing on shareholder-level taxation. Christopher H. Hanna of the Senate Finance Committee delivered the symposium’s opening remarks, with a major focus on how the… – Continue reading
Companies doing business in Luxembourg will be required to file global tax information now that the nation has released draft legislation to implement new international tax reporting rules. The rules—known as country-by-country reporting—would require companies to submit a global blueprint outlining the location of their operations, taxes paid, income earned,… – Continue reading
Coles has urged its German rival Aldi to sign up to a new tax transparency code that will lead to more big businesses, particularly multinationals, releasing detailed information about the tax they pay. Aldi has yet to sign up to the Voluntary Tax Transparency Code, which targets more than 1500… – Continue reading
Apple CEO Tim Cook struck back at critics of the iPhone maker’s strategy to avoid paying U.S. taxes, telling The Washington Post in a wide ranging interview that the company would not bring that money back from abroad unless there was a “fair rate.” Along with other multinational companies, the… – Continue reading
In May 2016, the Cambodian and Singaporean government authorities signed a new agreement to avoid double taxation with respect to taxes on income and on capital. What are the objectives and benefits of a double taxation avoidance (DTA) agreement? The “big-picture” objectives of the DTA between Singapore and Cambodia are… – Continue reading
The National Tax Service (NTS) Seoul Regional Office has been probing into a Korean processed food maker Paldo Company Ltd. since June on possible overseas tax evasion. According to the NTS Sunday, it has deployed international transaction investigators to investigate whether the instant food maker manipulated its transfer price to… – Continue reading
