International tax update- September 2015
New Zealand: GST and the digital economy
The New Zealand Government has released a Discussion Document regarding the proposal to impose goods and services tax (GST) on online purchases of goods and services from offshore suppliers by New Zealand resident consumers. The publication Taxing by the megabyte: New Zealand’s GST in our digital economy, examines the Discussion Document in detail, and encourages interested parties to consider making submissions by the 25 September 2015 closing date.
United Kingdom
Her Majesty Revenue & Customs (HMRC) has released a consultation document regarding the following three proposals to improve large business tax compliance:
- a legislative requirement for all large businesses to publish their tax strategy, enabling public scrutiny of their approach towards tax planning and tax compliance
- a voluntary ‘Code of Practice on Taxation for Large Business’, which sets out the behaviours which HMRC expects from its large business customers, and
- a narrowly targeted ‘Special Measures’ regime to tackle the small number of large businesses that persistently undertake aggressive tax planning, or refuse to engage with HMRC in an open and collaborative manner.
If you have any queries in relation to these proposals, contact Rob Hines on +61 (2) 8266 0281 or at robert.hines@au.pwc.com.
Transfer pricing and Advance Pricing Arrangements
This Tax Insights publication highlights the new guidance from the Australian Taxation Office (ATO) on Advance Pricing Arrangements.
Transfer pricing and CbC reporting
This Tax Insights publication provides an overview of the draft legislation released on 6 August 2015 to implement in Australia, the new transfer pricing documentation standards of the Organisation for Economic Cooperation and Development (OECD), including Country-by-Country, Master File and Local file reporting.
Exchange of information and implementing the OECD global standard
On 7 August 2015, the OECD released the following three reports to assist jurisdictions and financial institutions to implement the OECD global common reporting standard (CRS) for automatic exchange of financial account information:
- Standard for Automatic Exchange of Financial Account Information in Tax Matters: Implementation Handbook (the CRS Handbook): provides practical guidance for implementation of the CRS to help financial institutions and governments implement the CRS more efficiently by promoting the consistent use of optional provisions, identifying areas for alignment with the Foreign Account Tax Compliance Act of the United States ( FATCA), and addressing the operational and transitional challenges resulting from the staggered implementation of the CRS
- Update on Voluntary Disclosure Programmes: A Pathway to Tax Compliance: contains practical experience from 47 countries in relation to their voluntary disclosure programmes. The guidance on the design and implementation of such programmes has been updated, particularly taking into account the views of private client advisers.
- Model Protocol for the purpose of allowing the automatic and spontaneous exchange of information under a TIEA: this report provides the basis for jurisdictions wishing to extend the scope of their existing tax information exchange agreements (TIEAs) to also cover the automatic and/or spontaneous exchange of tax information.
