Category: Tax Planning

Transfer pricing not always tax evasion

The misconceptions about transfer pricing being a tax avoidance or violation in Vietnam are creating challenges for multinational enterprises, said Adam Sitkoff, executive director of the American Chamber of Commerce in Vietnam (Amcham). In his opening speech at a workshop held to gain clarity on the changing world of transfer pricing,… – Continue reading

China’s IIT Reform: Seven Key Points from the Draft Implementation Rules

Many taxpayers in China have had questions about how the government would change the individual income tax (IIT) law since the amendment was passed earlier this year. Recently, however, the tax authorities released a draft of the amendment’s implementation rules and measures for comment. While the draft implementation rules and… – Continue reading

Creditsafe pays £1m to HMRC under ‘Diverted Profits Tax’

Caerphilly-based credit referencing company Creditsafe has paid Her Majesty’s Revenue and Customs almost £1 million after it was served with a ‘Diverted Profits Tax’ charge. Registered as Creditsafe Business Solutions, the company, based at Caerphilly Business Park, sells business data for credit check purposes and other uses. According to full… – 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

Nigeria seeks IMF’s support on tax collection

The Federal Government is seeking assistance from the International Monetary Fund (IMF) on modalities for improving tax collection, especially from the International Oil Companies (IOCs), Finance Minister Zainab Ahmed, has said. She told reporters on the sidelines of the ongoing 2018 International Monetary Fund (IMF)/World Bank Group Meetings, in Bali,… – Continue reading

Tax Avoidance Taskforce helps net $5.6 billion in first two years

The more detailed scrutiny of the tax affairs of multinationals, large corporations and wealthy individuals, made possible by the formation of the Tax Avoidance Taskforce, has collected $5.6 billion in extra tax in just two years. Deputy Commissioner Mark Konza said “the $679.9 million the Government funded the ATO for… – Continue reading

Tax agency to inspect underperforming foreign firms

The General Department of Taxation has been reviewing press information about foreign firms continuously reporting loss to have inspection plan in the upcoming time. The general department has required tax agencies to focus on inspection over these companies. According to articles published on Sai Gon Giai Phong Newspaper in May… – Continue reading

FDI policy shift aims to support domestic firms

Viet Nam News HÀ NỘI —Vietnam will institute new policies designed to attract foreign direct investment (FDI) by boosting the development of local companies and setting up value chains driven by advanced technologies. FDI has been a major factor in Vietnam’s rapid socio-economic development; however, some key metrics remain below… – Continue reading

NBI probe in Turku targets real estate firm, nabs third suspect

A large-scale police operation into money laundering appears to have targeted the Airiston Helmi real estate firm, led by a Russian man with Maltese citizenship. An exceptionally large police operation took place in southwest Finland this weekend, in what the National Bureau of Investigation (NBI) said was an extensive search… – Continue reading

Sweden takes measures to tackle tax evasion, financial crimes

STOCKHOLM, Sept. 4 (Xinhua) — The Swedish government has proposed three new measurements to tackle aggressive tax planning, evasion and financial crimes, the Government Offices of Sweden said Tuesday. The proposals include increased international automatic information exchange, new possibilities for the Swedish Tax Agency to prevent financial crimes and tighter… – Continue reading

NBR’s transfer pricing cell remains ineffective for 5yrs

Transfer pricing cell of National Board of Revenue has remained nearly dysfunctional since its formation five years back due mainly to lack of logistic support, expert and dedicated manpower and propelling initiative of the tax authorities. The cell even could not conduct audit on any statement of international transactions of… – Continue reading

The best-known transfer pricing cases in Vietnam

VietNamNet Bridge – Nearly 38 percent of foreign invested enterprises (FIEs) reported losses in 2017, a significant decrease from the 50 percent seen in previous years. However, transfer pricing by FIEs remains a headache for management agencies. Do Thien Anh Tuan of Fulbright University said that enterprises that most regularly… – 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

IRS changes CAP program for large corporate taxpayers

The Internal Revenue Service is making some adjustments to its Compliance Assurance Process, a program aimed at large corporate taxpayers that involves cooperating with the IRS before any audits. As part of the proposed changes, the IRS said Monday it will shift the start of the application period to Oct…. – Continue reading

Crypto Islands as Double Offshore

There is a small island in the Caribbean … You immediately imagine relaxation, a beach, palm trees. However today in these small areas a really big crypto history is being created. The crypto business is increasingly mastering the jurisdiction of “dwarf” states, such as Cyprus, Malta, Gibraltar, The Republic of… – Continue reading

Facebook, Coke could face tax hit after ruling against Medtronic

Last week, Medtronic Plc suffered a legal setback in its bid to avoid a $1.4 billion U.S. tax bill — a ruling that may have costly implications for other multinationals battling the Internal Revenue Service over the use of overseas payments to lower their taxes. Companies including Facebook Inc. and… – Continue reading

Booksellers urge government to ‘act quickly’ on ‘Amazon tax’

News that the government may bring in an ‘Amazon tax’ to help “rebalance the playing field” between physical and online retailers has been welcomed by booksellers. After department store retailer House of Fraser became the latest high street chain to go into administration on Friday (10th August) Philip Hammond said… – Continue reading

Intra-group Service Fee Treatment in China

Most multinational corporations (MNCs) charge their subsidiaries for services like human resources (HR) or information technology support. The subsidiary’s payment for these services is classed as intra-group service fees when they are made within same enterprise group. Because some businesses use this method to avoid tax and shift profits, tax… – Continue reading

Introduction of exit capital tax will attract attention of tax authorities to export-import companies – Expert

The introduction of an exit capital tax, envisaged by the draft law on amendments to the Tax Code of Ukraine regarding the tax on exit capital (No. 8557), will draw the attention of tax authorities to companies carrying out foreign economic operations, expert for transfer pricing at Evris law firm… – Continue reading

PM asks authorities to probe tax evasion by FDI firms

Media reports have suggested the Government to build a more effective mechanism to tackle the problem that prolonged loss-making FDI enterprises have still enlarged investment and production. — Photo cafebiz.vn Viet Nam News HA NOI – Prime Minister Nguyen Xuan Phuc has assigned the Ministry of Finance (MOF) and General… – 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

Transfer pricing remains an issue

HCM CITY — Viet Nam’s laws about transfer pricing remain inconsistent and have many loopholes, causing great loss of State revenue, speakers said on July 19 at a meeting held in Ha Noi. Speaking at the “Transfer Pricing – Issues in Management” workshop, Dr. Ho Duc Phoc, auditor general of… – 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

The use of UK holding companies in international group structures – tax considerations

From a commercial viewpoint it is important that the Holdco is located in a reputable jurisdiction when seeking to access international equity and debt capital markets. The choice of Holdco location will also be relevant in circumstances where private equity investment is envisaged or where a trade sale is planned…. – Continue reading

Tax, investment changes concern foreign firms

Hanoi (VNS/VNA) – The changes in tax policy and investment incentives are the issues of greatest concern for foreign investors in Vietnam, said Bui Ngoc Tuan, Deputy General Director of the Audit and Advisory firm Deloitte Vietnam at a workshop on in Hanoi on July 10. Themed “Investment incentives, related… – 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

Transfer pricing disputes: Interest payout relief coming for MNCs

CBDT issues draft notification on interest computation NEW DELHI, JUNE 20 The Central Board of Direct Taxes (CBDT) proposes to provide a relief to MNCs on the interest payable by them on the untaxed profits stashed abroad, requiring to be repatriated back to India under the transfer pricing regime. It… – Continue reading

Tax Havens Are Not All Villains, Claims Study

Offshore finance centres are not the hotbeds of tax evasion everyone seems to believe, according to a new study. Debunking myths about tax havens, think tank the Institute of Economic Affairs argues tax havens have a key economic function helping the wealthy and businesses with tax planning. And although this… – Continue reading

Surveys Suggest Taxpayers Satisfied With TCJA, Says Hatch

Both large and small businesses in the United States expect the measures included in the recently enacted tax reform legislation, the Tax Cuts and Jobs Act of 2017, to have a positive effect on their operations, according to Senate Finance Committee Chairman Orrin Hatch (R-UT). In a recent statement, Hatch… – 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

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

Tax outflows, debt cripples Malawi’s growth

Malawi is struggling to address loss of revenues due to smuggling of minerals, unregulated artisanal and small-scale mining activities, under declaration of taxable income and transfer mispricing by mining companies. Reserve Bank of Malawi statistics show that Malawi lost $980 million (MWK78 billion) between 2010 and 2017 due to foreign… – Continue reading

HMRC To Add To Arsenal Against Diverted Profits

HM Revenue and Customs (HMRC) has launched a consultation inviting input on proposals to tackle arrangements entered into by individuals, partnerships, or companies that aim to move UK profits outside the scope of UK taxation, typically through the use of offshore trusts and companies. The new legislation, to be drafted… – Continue reading

OECD Releases More Transfer Pricing Country Guides

The OECD has published new transfer pricing country profiles for Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay, bringing the number of such overviews published by the OECD to 44. The profiles explain the current transfer pricing legislation and practices of each country…. – Continue reading

ZRA commended for exposing the tax evasion scam

The Centre for Trade Policy and Development (CTPD) has commended the Zambia Revenue Authority (ZRA) for exposing the tax evasion scam worth K76.5 billion in the extractive sector. The center has also welcomed intentions by the authority to undertake an extensive audit of mining companies. CTPD Executive Director Isaac Mwaipopo… – Continue reading

Indonesia Goes Hi-Tech in Hunt for Tax Assets After Amnesty

Jakarta. Indonesia’s tax office plans to spend hundreds of millions of dollars to update its outdated technology to boost low tax compliance and raise revenue collection in Southeast Asia’s largest economy, the country’s tax chief told Reuters. Indonesia completed one of the world’s most successful tax amnesties in 2017, but… – Continue reading

UK property tax changes affect GCC nationals

  PROPERTY in the UK, particularly London, has always been popular with GCC investors for many years. It has remained a safe haven and an attractive destination for investors and their families from the GCC region perhaps more than any other major city. Depending on the level of investment, well… – Continue reading

Court classifies medical firm tax planning as evasion

Tax authorities reviewed a case in which a doctor worked at a limited partnership firm and was paid via a limited liability company. The court described the arrangements as tax evasion. Many professionals would prefer to pay taxes on capital income because the tax burden is lighter than on earned… – Continue reading

Argentina Extends CbC BEPS Reporting Deadline

Argentina’s Federal Administration of Public Income has extended the filing deadline for country-by-country (CbC) notifications. Taxpayers who are part of multinational enterprises now have until May 2, 2018, to file CbC notifications where the ultimate parent company of the multinational group has a December 2017 fiscal year end. The CbC… – Continue reading

India Defers Surrogate Entity CbC Reporting Deadline

The Indian Central Board of Direct Taxes has issued a statement to defer the filing obligation on surrogate parent entities with regards to country-by-country reporting. Section 286 was inserted into the Income Tax Act 1981 through the 2016 Finance Act to introduce a requirement to furnish a country-by-country report. The… – Continue reading

Foreign groups in India have to provide country-by-country report, clarifies govt

All international groups operating in the country will have to provide a country-by-country (CbC) report as per the revised Income tax Act, the government clarified in a finance ministry release issued today. The CbC report is to be furnished by the ultimate parent entity of an international group in the… – Continue reading

UK’s Proposed Digital Tax ‘Would Cauterize Investment’

The introduction of a unilateral revenue tax on digital businesses in the UK would stymie investment and be a strangely timed gamble, says accountancy firm Moore Stephens. The Government’s position paper, “Corporate tax and the digital economy,” released at the recent Spring Statement, includes a proposal to tax certain tech… – Continue reading

Malta Backs EU Crackdown On Aggressive Tax Planning

Malta has reiterated its commitment to fighting aggressive tax planning, joining other EU member states who have unanimously agreed to amend the EU’s tax information sharing law, the Directive on Administrative Cooperation. The amendments to the Directive, which were agreed last week by EU finance ministers, will require intermediaries, such… – Continue reading

Mauritius Finalizes CbC Reporting Regulations

Mauritius last month released the Income Tax (Country-by-Country Reporting) Regulations 2018, setting out the jurisdiction’s rules concerning the filing by multinational groups of transfer pricing documentation. The CbC report is one element of a new three-tiered standardized approach to transfer pricing documentation proposed under BEPS Action 13. Under the framework,… – Continue reading

LUX RULES “MAY FACILITATE AGGRESSIVE TAX PLANNING”

The European Commission has criticised Luxembourg and six other EU member states for overly favourable tax treatment of multinational corporations. “The @EU_Commission is today stressing the issue of aggressive tax planning in seven EU countries: #Belgium, #Cyprus, #Hungary, #Ireland, #Luxembourg, #Malta and The #Netherlands. #FairTaxation,” Pierre Moscovici, the European finance… – Continue reading

Hong Kong Launches CbC Reporting Portal

Hong Kong’s Inland Revenue Department on March 5 launched its new Country-by-Country Reporting Portal. Groups can now register to file CbC reports for accounting periods beginning between January 1, 2016, and December 31, 2017, using the online portal. The CbC report is one element of a new three-tiered standardized approach… – Continue reading