HM Revenue and Customs has updated the International Tax Compliance Regulations to include provisions on new automatic tax information exchange agreements and to clarify how non-compliance penalties will apply. The amendment clarifies due diligence and reporting requirements for financial institutions, to ensure the UK complies with international tax reporting standards,… – Continue reading
Germany will introduce “license barrier rules” as of January 2018. The new rules will limit the tax deductibility of license fees or royalty payments to foreign related parties that benefit from preferential regimes (“Patent Box”, “IP-Box”, “License Box”) which are incompatible with the “OECD nexus approach” (“unqualified preferential regimes”) (sec…. – Continue reading
A newly published federal draft law introduces Russia to a three-tiered approach to transfer pricing documentation and brings Russian regulations in this area in line with the OECD minimum standards under Action 13 of the Base Erosion and Profit Shifting (BEPS) Action Plan. The draft law, published by the Ministry… – Continue reading
Many of the data submissions made by early adopters over the next two months under the new common reporting standard (CRS) are likely to be rejected and returned for correction and resubmission, adding to compliance costs, according to predictions from Sovos, a global tax compliance solution provider The UK is… – Continue reading
The Bahamas is under growing pressure to bow to international demands that it automatically exchange tax information on a ‘multilateral’ basis, with the European Union (EU) and its members refusing to accept this nation’s preferred approach. #Well-placed Tribune Business sources, both inside the Bahamas and internationally, have confirmed that the… – Continue reading
ISLAMABAD: Even before the formation of a seven-member joint investigation team (JIT) on the money trail of assets owned by Prime Minister Nawaz Sharif and his family, in accordance with the decision of the Supreme Court, new questions have arisen over its supposed modus operandi. The JIT team will not… – Continue reading
The United Arab Emirates (UAE) has signed an international tax agreement – Multilateral Convention on Mutual Administrative Assistance in Tax Matters(MAC), which is now seen as the ‘gold standard’ for co-operation in tax administration. With this move, UAE has become the 109th jurisdiction to join the most powerful multilateral treaty… – Continue reading
On 12/29/2016, Colombia’s Congress approved “Law 1819 of 2016”. The new legislation is a structural tax reform primarily aimed at increasing revenues for Colombia. Colombia suffered a loss of revenues when crude oil prices plummeted beginning in 2014. The loss of revenue created a negative impact on its economy; creating… – Continue reading
Approximately 300 participants, representing over 100 delegations from countries, jurisdictions, and international organizations gathered in Paris for the fourth meeting of the OECD Global Forum on VAT on April 12-14, 2017. The keynote address was delivered by Wang Jun, China’s Minister of Taxation, who discussed the implementation of value-added tax… – Continue reading
SEOUL, April 16 (Yonhap) — South Korea’s tax burden, which has steadily risen over the years, still remains among the lowest among the group of developed market economies with high income, data showed Sunday. Data by the Paris-based Organization for Economic Cooperation and Development (OECD) showed that the tax burden… – Continue reading
The German Ministry of Finance has published a progress report on its 10-point plan to combat tax evasion, which was first announced in the wake of last year’s Panama Papers leak. The plan, launched on April 12, 2016, outlines the measures that Germany wants to put in place at domestic… – Continue reading
A parliamentary commission will consider the introduction of a new legal obligation for tax advisers to disclose information about advice on tax mitigation to the Swedish Tax Agency, Skatteverket. Under the proposed rules, tax attorneys would be required to provide details of which clients have received advice on tax reduction… – Continue reading
SIX Financial Information announced that has launched a new Common Reporting Standard (CRS)/ Automatic Exchange of Information (AEoI) data service, enabling financial institutions to meet the requirements which are being phased in from June 2017. The SIX CRS/AEoI service identifies CRS-reportable client income by flagging relevant corporate actions, simplifying resource-intensive… – Continue reading
A report released Tuesday shows that Greece is among the countries of Organization for Economic Cooperation and Development (OECD) with the highest tax wedge – the difference between before-tax and after-tax wages, including the tax paid by both the employee and the employer. In the OECD report “Taxing Wages 2017,”… – Continue reading
With a total of 15 action points, the OECD’s Base Erosion and Profit Shifting (BEPS) project aims at fighting the artificial shift of profits from jurisdictions with high taxes to tax havens, often as a part of an entirely legal strategy used by MNEs. The BEPS Action 13 (Transfer Pricing… – Continue reading
As a rule and according to Article 33 of the Cyprus Income Tax Law, which introduces the arm’s length principle (using wording similar to that of article 9 of the OECD Model Tax Convention), all transactions between companies, including loan agreements/transactions by Cyprus companies, must be undertaken at arm’s length… – Continue reading
ANALYSIS: US-style deferred prosecution agreements (DPAs) should be introduced in Scotland to deal with corporate offending, according to a recent report by the global Organisation for Economic Cooperation and Development (OECD). Foreign bribery should attract significant penalties, and Scotland’s civil settlement regime is potentially too lenient, according to the report,… – Continue reading
New Zealand has asked taxpayers for input on countries that lack the safeguards to ensure information automatically exchanged under the Common Reporting Standard (CRS) remains confidential. To comply with the new international tax information exchange standard developed by the OECD, the CRS, New Zealand must publish a list of jurisdictions… – Continue reading
The OECD effort to rebuild the global tax system should focus on practical work that benefits the international tax community rather than trying to get as many countries as possible around the table, a former Treasury official said. The OECD’s so-called inclusive framework for implementing the four minimum standards of… – Continue reading
Part 2: Transfer Pricing documentation requirements From 1 April 2017, BEPS action 13 guidelines on transfer pricing (TP) documentation will be effective in Sweden. Action 13 is an effort to make MNEs global financial situation more transparent. It is a three-tiered based approach including a master file, local files and… – Continue reading
Governments around the world are losing as much as half a trillion US dollars (£400 billion) a year in tax revenue due to so-called “profit shifting” by multinational companies, according to research. The research published by the Tax Justice Network found that poorer countries were hardest-hit by the practice, which… – Continue reading
ISLAMABAD: After Federal Minister for Finance Ishaq Dar took a ‘principled stand’, Pakistani and Swiss authorities are scheduled to ink a revised convention on avoidance of double taxation agreement today (Tuesday) here in the federal capital, enabling the Pakistani authorities to get information about dirty untaxed money of $200 billion… – Continue reading
The European Parliament’s Panama Papers investigative committee is preparing for a “fact-finding” visit with counterparts in the U.S. Congress, as well as officials from the Treasury Department and Internal Revenue Service. The European Union lawmakers’ four-day U.S. trip, which begins March 21, will include a visit to Delaware for meetings… – Continue reading
The OECD and the International Monetary Fund have submitted to the Group of Twenty (G-20) nations a report on improving tax certainty for businesses. The report follows a global survey of more than 700 large, multinational businesses and a survey of 25 advanced nation tax administrations. The report highlights several… – Continue reading
Spain could make its tax system more efficient by scrapping income tax exemptions and by increasing value-added tax and environmental taxes, a new report from the OECD says. The OECD’s latest Economic Survey for Spain added the country should reduce employer social security contributions for low-wage workers on permanent contracts… – Continue reading
Tax reform is widely expected under the Trump administration by the corporate tax executives polled by BDO USA in a new survey. BDO’s 2017 Tax Outlook Survey polled 100 tax executives at public companies across the U.S., and found that 100 percent of the surveyed tax executives believe tax reform… – Continue reading
Finance Minister Ishaq Dar on Wednesday told the National Assembly that Pakistan will sign an agreement with Switzerland on exchange of information regarding bank accounts on March 21. “The Swiss government offered to sign such an agreement with Pakistan in the third quarter of the current month that will enable… – Continue reading
Romania approved legislation to join the OECD’s base erosion and profit shifting Inclusive Framework on March 2. As an Associate member under the Inclusive Framework, Romania will work on an equal footing with other associates and G-20 and OECD countries in the development of further BEPS standards and the peer… – Continue reading
Under increasing international pressure, the Hong Kong government is considering expanding its Automatic Exchange of Information (AEOI) implementation by imposing broader information collection obligations, entering into more bilateral AEOI agreements at a faster pace, and possibly joining the multilateral AEOI agreement. Background Hong Kong legislated to adopt the OECD Common… – Continue reading
Recently, the Finance Committee concluded its deliberations regarding the imposition of tax legislation pertaining to “wallet companies” (companies owned by individuals who provide services through them) within the scope of the Arrangements Law for 2017 – 2018. The original draft bill was softened and even sweetened for a particular period… – Continue reading
THE ORGANISATION for Economic Cooperation and Development (OECD) initiated the base erosion and profit shifting (BEPS) project in 2013 to address perceived gaps in international tax rules causing a loss of revenues for governments of about US$100 billion to $240 billion (Bt3.5 trillion to Bt8.4 trillion) annually. The OECD’s BEPS… – Continue reading
The Netherlands is slowly but surely steering away from facilitating the use of its corporate income tax system by companies that are set up merely to obtain tax benefits. These companies, which often do not actually carry out activities in the Netherlands, have contributed to the perception among policy makers… – Continue reading
U.S. multinational companies with more than $850 million in annual consolidated gross income now have draft instructions for filing IRS reports on their global tax and profits. The Internal Revenue Service added instructions to the draft Form 8975 and accompanying draft Schedule A it released in December 2016, companies that… – Continue reading
Brazil’s federal revenue service is continuing to adapt the country’s tax rules to OECD recommendations, as shown in recent guidance on how companies should seek help from the government on international tax questions. Normative Instruction 1689, issued Feb. 21, spells out the requirements for companies to request a consultation on… – Continue reading
President of Panama Juan Carlos Varela signed into law today the implementation of the Convention on Mutual Administrative Assistance in Tax Matters (MAC), which allows for sharing tax information multilaterally on request with the 107 jurisdictions that are part of the convention and provides a common legal basis for cooperation… – Continue reading
Finance Minister Edward Scicluna presented amendments to rules against tax avoidance practices within the ECOFIN Council today, amounting to a compromise solution which was accepted. The solution provides rules regarding corporate hybrid mismatches and third countries. The Council agreed its position on rules aimed at closing down ‘hybrid mismatches’ with… – Continue reading
Irish Finance Minister Michael Noonan has criticized the EU’s proposals for a common consolidated corporate tax base (CCCTB) and public country-by-country (CbC) reporting as “against the BEPS consensus.” In a speech to an event on corporation tax, Noonan said that the consensus over the OECD’s BEPS proposals must hold and… – Continue reading
As part of the global transparency push, the G20 has committed to implement rules requiring the disclosure of beneficial ownership of legal entities (in addition to automatic exchange of financial account information and the BEPS related transparency measures). On 13 February 2017, Treasury released a consultation paper dealing with part… – Continue reading
In the public vote held on February 12, 2017, Swiss voters rejected the Corporate Tax Reform III Law Proposal (CTR III). Nevertheless, this issue is not yet resolved and remains on the table! A «CTR III 2.0» is expected in a timely manner. Information about the newest developments, but also… – Continue reading
Italy must reform its banking system if it is to continue on a “weak” path to recovery, according to the Organisation for Economic Co-operation and Development (OECD). The country should be prepared to force holders of Italian bank debt to lose money rather than using public funds to bail them… – Continue reading
The OECD has recommended that Sweden rebalance its property tax system. In its latest Economic Survey for the country, the OECD said that Sweden’s favorable tax treatment of owner-occupied housing is regressive, benefiting relatively high-income households most and contributing to the high demand for housing. It said it also encourages… – Continue reading
Selection of Foreign Company as a tested party – practical considerations Introduction Transfer pricing regulations adopted by India are based on the arm’s length principle which revolves around the concept that the price or margin determined in a controlled transaction involving two Associated Enterprises (AE) should be commensurate with an… – Continue reading
The Government has introduced the Diverted Profits Tax Bill 2017 and the 35 page Treasury Laws Amendment (Combating Multinational Tax Avoidance) Bill 2017 into Parliament to implement the Diverted Profits Tax (DPT), as one of its first Parliamentary items of business in 2017, indicating the priority attached to this measure…. – Continue reading
The Irish tax agency has updated its guidance on the automatic exchange of information on tax rulings between EU member states. Changes have been made to the Tax and Duty Manual to set out Revenue’s arrangements for implementing Council Directive (EU) 2015/2376 and the OECD’s framework for the compulsory spontaneous… – Continue reading
With the arrival of the new year, don’t be surprised if your bank asks for information about yourself and your accounts that you didn’t have to provide before. These questions signal an important development as banks in Hong Kong and around the world prepare to share certain information with tax… – Continue reading
NEW YORK, Feb. 7, 2017 /PRNewswire/ — KPMG LLP, the U.S. audit, tax and advisory firm, has issued a new survey report on the international Common Reporting Standard (CRS), which reveals that financial institutions impacted by the regulations still have much work to do to meet with the initiative’s significant… – Continue reading
Swiss voters will vote next week on whether to reform corporate tax and remove the reduced tax rates that Switzerland currently grants to multinational firms. Voters will be asked whether they accept the federal law that was adopted by Switzerland’s national council in June 2016 “with a view to enhancing… – Continue reading
India has revised 40 treaties for avoidance of double taxation so that the information exchanged with partner nations on tax matters can also be utilised for other purposes including criminal proceedings, Parliament was informed on Friday. “Treaty partner countries have been requested to modify the tax treaties, so as to… – Continue reading
The OECD made its end-November 2016 deadline to release the text of the multilateral treaty to give effect to the BEPS Actions which involve changes to tax treaties, see here. The 49 page treaty text, which is commonly referred to as the multilateral instrument or MLI, and 85 page explanatory… – Continue reading
Indonesia has entered the third phase of its tax amnesty program, which was first launched in July 2016 to boost the country’s meagre revenue by collecting previously unreported funds hidden by wealthy citizens abroad and at home. The country, which has long struggled to increase its tax revenue, has so… – Continue reading
