Category: KPMG

ITALY: INCOME TAX TREATY WITH HONG KONG ENTERS INTO FORCE

An income tax treaty between Italy and Hong Kong has entered into force, with the exchange of instruments of ratification. The official communication of the Italian Ministry of Foreign Affairs announcing this exchange was published in the official journal on 26 October 2015. BLACK LIST, WHITE LIST Italy’s “black list”… – Continue reading

Australia out of step with global corporate tax rate trends

Australia’s corporate tax rate is higher than the global average, according to KPMG’s 2015 global tax rate survey, SmartCompany reports. While Australia’s corporate tax rate currently sits at 30 per cent, the global average sits at 23.68 per cent. The United States has the highest corporate tax rate at 40… – Continue reading

HUNGARY: IMPLEMENTING TRANSFER PRICING-RELATED BEPS ACTIONS

Action 13 of the final package of reports issued by the Organisation for Economic Cooperation and Development (OECD) under the base erosion and profit shifting (BEPS) project focuses on a company group’s global value chain and transfer pricing policy, and introduces a standardized three-tiered approach to transfer pricing documentation—core documentation… – Continue reading

FRANCE: RECENT TRENDS IN TRANSFER PRICING, SURVEY

The European Commission recently published new rulings, the OECD published its base erosion and profit shifting (BEPS) final reports, and many countries are reviewing and reinforcing their transfer pricing rules—and France is no exception. Tax professionals in France have observed certain recent trends with regards to transfer pricing. The current… – Continue reading

CHANNEL ISLANDS: CRS MEASURES IN JERSEY

Pending draft regulatory measures in Jersey would give effect to the Common Reporting Standard (CRS). In general, the draft regulations would impose an obligation on “reporting financial institutions” in Jersey to identify, review, and report on “financial accounts” maintained by these institutions of accounts held by residents for tax purposes… – Continue reading

Shell companies’ patents to come under domestic tax net on adoption of BEPS

MUMBAI: Technologies that are developed in India but their patents registered in tax havens may come under the domestic tax net from the next financial year, when the country is expected to adopt a new world standard aimed at preventing abuse of double taxation avoidance agreements. Many multinational and local… – Continue reading

EU: “TAX RULINGS” IN LUXEMBOURG, NETHERLANDS DEEMED ILLEGAL STATE AID

The European Commission today announced a decision that Luxembourg and the Netherlands granted selective tax advantages to two multinational corporate entities, and as such, these “tax advantages” are illegal under EU state aid rules. The EC concluded that the tax rulings granted by the tax authorities in Luxembourg and in… – Continue reading

OECD crack down on corporate tax shelters is a risky double edged sword

Companies who have been accused of shifting profits to low-tax jurisdictions or those seeking tax shelters need to beware—these practices are coming under fire, and could possibly come to an end. The Organization for Economic Cooperation and Development (OECD) just released details of their far-reaching plan that would require companies… – Continue reading

As tax havens disappear, global revenue wars begin

We are entering a new world of tax revenue wars, and no one can say who will emerge as the victor. All we know is that there will be tension over the next five years as governments seek to implement the global plan to end to tax havens from Luxembourg… – Continue reading

Is a Canada Revenue Agency landlord avoiding taxes via offshore havens?

The Canada Revenue Agency (CRA) rents office space from a Vancouver-based property developer – a company that exploits offshore tax havens in Liechtenstein, the British Virgin Islands and Channel Islands. Larco Investments Ltd. owns three buildings in Montreal, Calgary and Edmonton where they rent office space to the CRA. Larco… – Continue reading

BEPS: CURRENT STATUS OF IMPLEMENTATION IN VARIOUS COUNTRIES

Last week’s OECD release of the final package of measures for a coordinated international approach to the reform of the international tax system, under the OECD/G20 base erosion and profit shifting (BEPS) project, marks the end of the discussion and recommendation phase, and the start of the implementation and practical… – Continue reading

Beyond the Black Money Bill

No focus on stock markets and other money-laundering machines After all the noisy assertions, only Rs4,147 crore of unaccounted wealth was declared during the special 90-day compliance window of the The Undisclosed Foreign Income and Assets (Imposition of Tax) Act, 2015 (Black Money Bill). Of this, just Rs2,488 crore will… – Continue reading

Companies ‘are scrambling to boost tax transparency amid global crackdown’

Companies around the world are scrambling to overhaul how they communicate with the public when it comes to how much tax they pay, according to professional services firm KPMG. While the Senate is currently investigating multinational firms such as Apple and Google over potential tax avoidance, other countries are also… – Continue reading

CAYMAN ISLANDS: UPDATE ON CRS IMPLEMENTATION, REGULATIONS

The Cayman Islands Tax Information Authority is moving forward with its plans for implementing the OECD Common Reporting Standard (CRS). The Cayman Islands was a signatory to CRS when released in October 2014. he Cayman Islands tax authority in September 2015 released a draft version of regulations—Tax Information Authority (International… – Continue reading

KPMG Webcast Will Examine OECD’s Final Recommendations On Base Erosion And Profit Shifting Initiative

NEW YORK, Oct. 9, 2015 /PRNewswire/ — KPMG’s Tax Governance Institute (TGI) will examine the final recommendations from the Organisation for Economic Co-operation and Development (OECD) on Base Erosion and Profit Shifting (BEPS) and discuss what they could mean for U.S. multinationals during a live video webcast on Tuesday, Oct…. – Continue reading

KPMG Statement On OECD’s Final Recommendations On Base Erosion And Profit Shifting (BEPS) Initiative

NEW YORK, Oct. 5, 2015 /PRNewswire/ — The following statement is being issued today by KPMG LLP on the final recommendations released on Oct. 5 by the Organisation for Economic Co-operation and Development (OECD) on its coordinated Action Plan on Base Erosion and Profit Shifting (BEPS): “The OECD’s final recommendations… – Continue reading

EXCLUSIVE: KPMG tax ‘sham’ used by at least 25 wealthy Canadians, document says

At least 25 multi-millionaire Canadians used an offshore “sham” set up by accounting firm KPMG, a document filed Tuesday in Federal Court shows. For more than two years, KPMG has been fighting a court order to provide the list of names of multi-millionaire clients who had used what the CRA… – Continue reading

EXCLUSIVE | Cabinet ministers met publicly with KPMG while firm’s tax ‘sham’ under CRA probe

Accounting firm joined revenue minister at speech while fighting court order Top Conservative cabinet ministers met publicly with senior staff from KPMG’s tax division, and one went so far as to promote the firm, even as the Canada Revenue Agency was alleging the company set up an offshore tax “sham”… – Continue reading

CHINA: TRANSFER PRICING DISCUSSION DRAFT; BEPS INFLUENCE

China’s State Administration of Taxation on 17 September 2015 released a discussion draft of proposed guidance relating to “special tax adjustments”—including those concerning transfer pricing—for public consultation. It is anticipated that this guidance could be finalized by the end of 2015, and once final, would replace the existing transfer pricing… – Continue reading

KPMG offshore ‘sham’ deceived tax authorities, CRA alleges

A wealthy Victoria, B.C., family paid virtually no tax over a span of eight years – and even obtained federal and provincial tax credits – while being involved in an offshore tax “sham” developed by one of the country’s most respected accounting firms, the Canada Revenue Agency alleges. The Canada… – Continue reading

CHINA: MANAGING IP TAX CHALLENGES IN BEPS ENVIRONMENT

Multinational enterprises (MNEs) producing or selling their products in China have had to contend with the commercial, legal, and tax challenges of managing how their intellectual property (IP) is used in relation to their Chinese operations. Regulatory approvals for joint ventures operating in China have often required that IP rights… – Continue reading

Switzerland: Innovation tax breaks “key to attracting companies”

Industry lobby groups are calling on lawmakers to bolster business innovation as they debate corporate tax reforms aimed at retaining Switzerland’s status as a location for multinationals, reports Swiss Info. Parliament is currently looking at a government recommendation to replace Switzerland’s current, and controversial, cantonal corporate tax system – that… – Continue reading

US: Explanation of competent authority revenue procedure

The IRS on 12 August 2015 released Rev. Proc. 2015-40 with respect to requesting competent authority (CA) assistance, and it is generally effective for CA requests filed on or after 30 October 2015. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54. The IRS concurrently released Rev. Proc. 2015-41 as… – Continue reading

Islamic banking ‘a possible option’ for BMIO as reorganization plan is implemented

(Seychelles News Agency) – Onshore banking activities, including the possibility of introducing Sharia-compliant banking are being considered for the Seychelles-registered Bank of Muscat International Offshore (BMIO). The Al Salam Bank of Bahrain, which now owns 50 percent shares in the Seychelles-registered Bank is engaging with the Seychelles authorities on the… – Continue reading

Getting to Grips with How Latin America’s Tax Laws Impact Outsourcing Operations

With different tax laws, exemptions, double taxation treaties and free trade zones for services exports affecting outsourcing operations across Latin America, gaining a solid understanding of the distinct tax obligations in each country is imperative. In a bid to attract investment, several Latin American countries have introduced double taxation treaties,… – Continue reading

Austria – Tax legislative changes, effective January 2016

July 22: Tax legislative changes in Austria were passed by the parliament, and the effective date for most changes is 1 January 2016. Among the provisions are the following items. Withholding tax on dividend distributions, capital gains The withholding tax rate for dividends and capital gains will be increased to… – Continue reading

Tax disclosure programme has some flaws, say experts

HE Voluntary Disclosure Programme introduced in 2012 to encourage taxpayers to regularise their affairs has some flaws that need addressing to be able to expose the real amount of money that has left SA illegally. Tax experts warn that the process in SA is relatively expensive, there are uncertainties because… – Continue reading

KPMG And Dun & Bradstreet Alliance Addresses FATCA Due Diligence Challenges

NEW YORK and SHORT HILLS, N.J., June 30, 2015 /PRNewswire/ — Marking the one-year deadline for foreign financial institutions (FFIs) to identify their preexisting entity account base for purposes of the Foreign Account Tax Compliance Act (FATCA), KPMG LLP, the U.S. audit, tax and advisory firm, and Dun & Bradstreet… – Continue reading

Supreme Court says Pendragon’s dealerships accountable after finding demonstrator VAT scheme was “abusive” of the law

The UK’s Supreme Court has ruled that a KPMG scheme to enable dealer group Pendragon to recover VAT on demonstrator cars sold as used cars was “abusive” of the law. Its decision earlier this month has overturned a previous Court of Appeal ruling on the scheme, which Pendragon used on… – Continue reading

Crackdown on multinational tax avoidance likely to be thwarted, says expert

The G20’s efforts to crack down on multinational tax avoidance are likely to be defeated by national self-interest, particularly from the United States, one of Australasia’s top tax advisers says, reports the Sydney Morning Herald. Rod Houng-Lee, formerly Asia Pacific Tax Leader head of tax in Asia Pacific for big-four… – Continue reading

IBFD holds first-ever Africa tax symposium

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

OECD – Initial impressions, BEPS Action 8 (hard-to-value intangibles)

June 5: The Organisation for Economic Co-operation and Development (OECD) yesterday released a discussion draft concerning work in relation to Action 8 under the base erosion and profit shifting (BEPS) project concerning hard-to-value intangibles. Read the BEPS Action 8 discussion draft [PDF 62 KB] The following discussion provides initial impressions… – Continue reading

Island’s links with the Northern powerhouse worth promoting

A full and fascinating roundtable discussion based around the island’s place as an international finance centre was held at KPMG’s headquarters in Athol Street, Douglas. Around the table were David Karran, managing director, IQE, Simon Scott, managing director, Barclays Isle of Man, Andrew Thomas, chief executive, Isle of Man Enterprises… – Continue reading

UK banks named in football bribery scandal: Barclays and HSBC ‘handled millions in suspect transactions’

■ Barclays and HSBC have been named in legal papers filed in the US ■ Documents have also named London-based Standard Chartered Bank ■ Allegedly moved suspect transactions linked to Fifa through their accounts ■ Britain’s Serious Fraud Office is understood to be monitoring situation Two of Britain’s biggest High… – Continue reading

Sean Foley,Global Leader, KPMG, says ‘India’s Transfer Pricing Rules Aggressive’

Even as the action plan to address Base Erosion and Profit Sharing (BEPS) is being worked out, multinationals are bracing for some turbulent times in India. For some time now, transfer pricing – the price of goods and services determined by a company when two of its subsidiaries transact –… – Continue reading

KPMG Responds To Hockey’s Tax ‘Integrity’ Measures

Grant Wardell-Johnson, KPMG Tax Partner, has said that while it would have been better for Australia to await the outcome of the OECD’s base erosion and profit shifting Action Plan, the international tax measures proposed recently by Treasurer Joe Hockey “have the benefit of being highly targeted.” On May 11,… – Continue reading

11th Circuit Punts Tax Shelter Question to Florida Justices

When should the beneficiaries of an IRS-targeted tax shelter be allowed to sue their enablers? That’s the question the federal appellate court in Atlanta posed to the Florida Supreme Court April 17 in an ongoing bankruptcy-related case. The answer, which turns on statutes of limitations, probably will boil down to… – Continue reading

Tax boss rebukes Google, Apple and Microsoft over Senate inquiry eviden

Commissioner Chris Jordan delivers rebuke to multinational tech giants contesting evidence they gave to a Senate inquiry into corporate tax avoidance The tax commissioner, Chris Jordan, has delivered a public rebuke to multinational tech giants Apple, Google and Microsoft, vigorously contesting evidence they gave to a recent Senate inquiry hearing… – Continue reading