The UK Government’s goal is to make the UK the best place in the world to locate an international business; it has one of the most open economies globally, a highly skilled workforce, access to capital markets, a first-class infrastructure, and a highly competitive corporate tax system. UK tax policy… – Continue reading
Ukraine’s Cabinet of Ministers will remove Austria from the list of countries transactions with whose counterparties are subject to control under the law on transfer pricing on August 1, 2015. This is stipulated in Cabinet resolution No. 677 dated July 1, 2015, which is available on the government website on… – Continue reading
The ATO is looking to catch more big-time tax cheats by hiring new specialist public servants, just months after paying more than 400 of them tens of millions of dollars to leave. The Tax Office is advertising technical specialist jobs at APS 6, EL1 and EL2 pay levels in two… – Continue reading
Access to company data is vital if policymakers are to understand how changing regulatory requirements influence performance Much focus has recently fallen on the issue of tax avoidance, as research on the subject has increasingly shown that the global economy is losing out on billions of dollars to a byzantine… – Continue reading
VANCOUVER, July 6, 2015 /PRNewswire/ – Silver Wheaton Corp. (“Silver Wheaton” or the “Company”) (TSX:SLW) (NYSE: SLW) announces that it has received a proposal letter dated July 6, 2015 (the “Proposal”) from the Canada Revenue Agency (the “CRA”) in which the CRA is proposing to reassess Silver Wheaton under various… – Continue reading
MUMBAI: The Central Board of Direct Taxes has signed a taxation rate agreement with BNP Paribas India Solutions, the local arm of the European bank, as part of efforts to reduce disputes with foreign companies over tax-related issues. BNP Paribas Solutions is the first company in the information technology and… – Continue reading
The Advance Pricing Agreement (‘APA’) program was introduced in August 2012. APA helps a tax payer to ascertain the transfer pricing between related party transactions upfront to avoid any litigation. The APA program has been a success and there has been a rise in the number of applications filed year… – Continue reading
On June 24, 2015, the World Customs Organization (WCO) published the WCO Guide to Customs Valuation and Transfer Pricing (the Guide). The primary purpose of the Guide is to assist customs officials in understanding the relationship between customs valuation and transfer pricing. However, the WCO also recommends members of the… – Continue reading
A firm directly involved in one of Europe’s largest tax scandals is now giving tax advice to the European Commission and member states. The audit firm, PricewaterhouseCoopers (PwC), sits in a group called the EU Joint Transfer Pricing Forum. The forum’s been around for years, but its mandate was recently… – Continue reading
On June 8th 2015, the OECD released a new package of measures for the implementation of a new Country-by-Country (CbC) reporting plan developed under the OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS) Project, aimed at improving transparency in international tax matters. The CbC reporting plan was founded… – Continue reading
Apart from placing full time expatriate employees in China, as an investor you may often need to send staff from the parent company to China to complete temporary projects. Common examples include quality control, engineering projects, training or consultancy. However, what many foreign investors don’t know is that such visits… – Continue reading
Multinational pharmaceutical companies are unable to assure Australians they are not being “ripped off” on the price of medicines as a result of their complex global supply chains. The Australian heads of nine of the biggest global drug suppliers were forced into the embarrassing admission on Tuesday after backing themselves… – Continue reading
OECD and G20 Action Plan on Base Erosion and Profit Shifting (BEPS) was adopted in 2013. It consists of 15 actions including transfer pricing, taxation of controlled foreign corporations (CFC), digital commerce, hybrid instruments, international information exchange, tax treaty shopping etc. In 2013, OECD working group prepared draft documents regarding… – Continue reading
The Executive Directorate of Revenue has announced that as part of the changes in the audit and tax collection system, it will oversee the transfer prices of companies headquartered abroad. In addition to the implementation of electronic billing and other changes that aim to improve the supervision of tax collections,… – Continue reading
Action 3 of the OECD’s Base Erosion and Profit Shifting (BEPS) agenda promised to address how countries could use controlled foreign corporation (CFC) rules to combat BEPS. Unfortunately (or fortunately, depending upon one’s vantage point), as is pretty much universally agreed, the OECD’s draft report on CFC rules (the “draft”)1… – Continue reading
The German government has announced plans to incorporate Action 13 (guidance on transfer pricing documentation and country¬by¬country (CbC) reporting) of the OECD’s BEPS project into local legislation. The wording of the new law is being drafted and may be published some time in autumn of this year. It is the… – Continue reading
VietNamNet Bridge – It is clear that the US has been increasing its investments in Vietnam and that Vietnam needs to grab the great opportunities brought by the capital flow. Dr Vu Chi Loc from the Hanoi Foreign Trade University noted that Vietnam’s deep integration into the global economy in… – Continue reading
OECD common reporting standard On 3 June 2015, the Treasurer announced that Australia had signed the Organisation for Economic Co-operation and Development’s (OECD) common reporting standard (CRS) Multilateral Competent Authority Agreement which enables automatic exchange of CRS information between countries. Australia proposes to implement the CRS from 1 January 2017,… – Continue reading
CUSTOMS and Excise would be adding four mobile container scanners that would become operational within the next two months. The scanners would be used for locating narcotics, arms and ammunitions and explosives as goods arrive in the country. Customs would also be acquiring six more sniffer dogs to assist its… – Continue reading
THE focus of a high-level inquiry into corporate tax avoidance will move to some of the globe’s biggest drug companies during hearings today. After revealing details of the tax minimisation strategies at Google, Apple and Microsoft, the Senate’s Standing Committee on Economics will hear from pharmaceutical executives in Sydney. Among… – Continue reading
A common mistake when analyzing the tax implications of a cross border transaction is to jump too quickly to the ramifications of a tax treaty without first having a clear handle on the tax implications under the Income Tax Act (Canada) (“ITA”). A related issue is that even though a… – Continue reading
By ESTHER MSETEKA, Mazabuka LUSAKA Stock Exchange (LuSE) chief executive officer Brian Tembo says there is need for Government to formulate a capital market policy that links foreign direct investment to listing. Mr Tembo said the country needs to find ways which can help create linkages between companies that invest… – Continue reading
Multinational drug companies are presenting a united front ahead of their appearance at the Senate’s corporate tax avoidance inquiry, insisting they are honest, ethical and pay their fair share of tax. Nine pharmaceutical companies, which between them receive billions of dollars in taxpayer-subsidised sales via the Pharmaceutical Benefits Scheme, will… – Continue reading
The Italian Supreme Court has ruled that transfer pricing adjustments applied by the tax authorities may be deemed legitimate even if they have been applied after a comparison between the transactions assessed and the ones carried out by and among third independent parties. In the case at issue, the tax… – Continue reading
Corporate entities are often deemed to be related in terms of excise law if (a) they are interconnected undertakings and / or (b) they have mutuality of interest in the business of each other. Excise and Customs law are the oldest surviving indirect tax legislations in India. Despite this, till… – Continue reading
The challenges faced by multinational enterprises (MNEs) in navigating the interface of transfer pricing and customs valuation rules is not a new phenomenon. However, due to a marked increase in recent years of the number of countries introducing or updating their transfer pricing legislation and scaling up their auditing and… – Continue reading
ICC has welcomed a new World Customs Organization’s (WCO) Guide to Customs Valuation and Transfer Pricing which includes ICC proposals for more coherent tax and customs revenue collection. Released this week as part of a new WCO Revenue Package, the new guide provides concrete guidance on revenue collection to governments… – Continue reading
When Indian President Pranab Mukherjee gave Finance Bill 2015 his assent on May 14, most provisions were largely hailed as improvements to the business environment in India. Others, while seen as primarily positive, have been the cause of some concern. One such provision changes the residency test for companies doing… – Continue reading
Nguyen Anh Tuan, head of the agency, said at a press conference in mid-May that there were signs of dairy manufacturers and distributors committing transfer pricing. The majority of materials and finished dairy products are imported from overseas for domestic production and distribution as directed by the foreign partners. Therefore,… – Continue reading
Thailand’s Council of State is deliberating the country’s first law on transfer pricing. If passed the bill w ould allow Thailand Revenue Department (TRD) officials to enquire into profits from crossborder transactions of multinational companies. The final draft of the law w as approved by the Cabinet in May this… – Continue reading
THERE have been a number of challenges in implementing the 2015 mining tax regime, says Zambia Revenue Authority commissioner general Berlin Msiska. And Msiska says there is an immoral aspect to tax avoidance, even if it might be said not to be illegal. Msiska said in an interview that tax… – Continue reading
Someone once said that a good tax system enables the government to pluck the feathers from the taxpaying goose with the least amount of hissing, says Rod Houng-Lee. The least amount of hissing occurs when the law is simple and clear. The hissing increases exponentially when the law is more… – Continue reading
MUMBAI: The Central Board of Direct Taxes (CBDT) recently issued clarifications on the rollback provisions available under the advance pricing agreement (APA) mechanism in the arena of transfer pricing. While some clarifications – such as availability of a rollback even when a revised income tax return is filed, or the… – Continue reading
International tax rules will soon change, but companies’ behaviour may change sooner. There will soon be fewer places for multinational companies and ultra-rich individuals to squirrel away money. In November leaders of the G20 are expected to adopt a full range of measures to curb the practices of base erosion… – Continue reading
In a further move to make tax systems fairer, more efficient, growth-friendly and transparent, the Commission presented an Action Plan to fundamentally reform corporate taxation in the EU and published a “Top 30” list of tax havens across the world. The Action Plan sets out a series of initiatives to… – Continue reading
The reported resurgence of cross-border mergers involving US companies that then move their corporate headquarters abroad shows that anti-tax avoidance measures passed last year were “a sticking plaster rather than a long-term solution”, an expert has said17 Jun 2015 The Financial Times reported (registration required) that demand for corporate ‘inversion’… – Continue reading
Indian Government has finally heeded the clarion call of the taxpayers who were besieged by transfer pricing adjustments.That said, while an earnest beginning has been made, it would bring the matter to a perfect close if the apparent deficiencies in the draft rules were to be addressed Since its introduction… – Continue reading
Tax avoidance can be defined as aggressive tax-planning strategies and structures by multinational companies that take advantage of the gaps or mismatches in tax rules to shift profits to low-tax locations. While many countries around the world have either general or specific anti-avoidance legislation to tackle this problem, the current… – Continue reading
Foreign companies are likely to be penalised for failing to submit statements of transactions above Tk 3 crore with their associated overseas entities. The National Board of Revenue took the measure to curb illicit fund transfers and tax evasion. The penalty will be equivalent to 2 percent of the value… – Continue reading
Zambia Revenue Authority -ZRA- Commissioner General Berlin Msiska says the authority has granted tax deferment to some mining firms following cash flow challenges in the sector. Mr. Msiska says the deferment was given after the said firms applied because of challenges facing the sector and was granted in accordance with… – Continue reading
Windhoek Namibia’s Inland Revenue has established a transfer pricing unit. “We will be asking you for transfer pricing supporting documents soon,” said Acting Commissioner for Inland Revenue, Justus Mwafongwe, at the recent annual tax symposium hosted by the PwC’s Namibia Business School. Mwafongwe confirmed that the draft amendment bills to… – Continue reading
Bring together an impressive group of respected tax professionals from all over Africa, International Bureau of Fiscal Documentation (IBFD) is set to hold “Africa Tax Symposium, Trends in International Taxation: An African Perspective,” from June 18-19, 2015 in Livingstone, Zambia. IBFD announces that its inaugural The two-day event will present… – Continue reading
The LuxLeaks financial scandal, which entailed disclosure by the International Consortium of Investigative Journalists of tax rulings, galvanized public opinion and gave rise to the creation of TAXE, the European Parliament’s special committee on tax rulings. This article explains why TAXE was created and shares with you highlights from the… – Continue reading
With revenue from petroleum taxes at its lowest point in fifteen years, Nigeria is under even more pressure to tackle tax evasion and pursue other revenue enhancing initiatives. Indeed, experts have found that tax evasion plays a significant part in the over $50 billion that the continent loses every year… – Continue reading
MUMBAI: With its subsidiary Cairn India facing Rs 20,495-crore tax notice, billionaire Anil Agarwal-led Vedanta Group today said it is “frustrated” by the tax demand raised on it using retrospective legislation. The Income Tax Department had in March slapped a Rs 20,495 crore tax demand on Cairn India for failing… – Continue reading
Transfer pricing has emerged as a key focus area both globally and locally. From an international scene, the OECD/G20 venture — a club of advanced countries in Europe and North America, has been working on action plans to help tax administrations deal with Base Erosion and Profit Shifting (BEPS) project…. – Continue reading
Multinational firms said to be ‘cheating’ African countries out of billions of dollars that could be used for health care and education. G7 leaders Monday pledged to reform the international tax system by minimizing transfer pricing, according to Public Finance International. Transfer pricing involves internal transactions between a large company’s… – Continue reading
The Diverted Profits Tax (DPT), known by many as the “Google Tax”, is intended to stop large groups diverting profits from the UK by seeking to avoid creating a UK permanent establishment or using arrangements or entities which lack economic substance to exploit tax mismatches. Tax mismatches occur where intra-group… – Continue reading
The Argentine Supreme Court ruling on Toepfer International, a commodity exporting firm, has finally been published, tw o months after the decision, providing lessons for BEPS action 10 (cross border commodity transactions). This case, AFIP v Alfred C Toepfer Internacional, belongs to the first group of three controversies, related to… – Continue reading
NEW DELHI — India’s goal of a friendlier tax regime for global companies to help power China-beating economic growth is hitting a manpower hurdle. Fewer than 20 officials face the complex task of working with hundreds of multinationals on pacts to avert tax rows, people familiar with the matter said,… – Continue reading
